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  • Case Opinion

Keister v. AARP Benefits Comm.

Keister v. AARP Benefits Comm.

United States District Court for the District of Columbia

October 7, 2019, Decided; October 7, 2019, Filed

No. 1:18-cv-2385 (KBJ)

Opinion

 [*247]  MEMORANDUM OPINION

Plaintiff Kim Keister worked as an employee of AARP, Incorporated, for approximately 12 years prior to having a stroke that allegedly required him to stop working. Keister first pursued long-term disability benefits under the company's disability benefits plan administratively, and he now seeks such relief from this Court. (See Compl., ECF No. 1.) Notably, back when Keister was unsuccessfully trying to secure disability benefits from AARP through the administrative process, he was also engaging in negotiations with AARP regarding the terms of his separation. To that end, in exchange for severance pay, Keister executed a separation agreement that included a "general release" and expressly waived "any and all claims" against AARP and certain other entities. (Ex. B to Aetna's [**2]  Reply in Supp. of Mot. for Summ. J. ("Release"), ECF No. 20-1, at 3, ¶ 2; see also id. at 5.)1 The instant complaint eventually followed; Keister alleges that defendant AARP Benefits Committee ("AARP Benefits"), which is the administrator of AARP's disability benefits plan, and defendant Aetna Life Insurance Company ("Aetna"), the insurer of that plan, have wrongfully denied him disability benefits that he is entitled to receive under the Employee Retirement Income Security Act of 1974 ("ERISA"), 29 U.S.C. § 1001 et seq. (See Compl. ¶ 1.)

Before this Court at present are two summary judgment motions that Defendants have filed, challenging Keister's right to pursue his disability benefits claim before this Court in light of the executed waiver. On September 30, 2019, this Court issued an Order that GRANTED both of Defendants' motions. (See Order, ECF No. 26.) This Memorandum Opinion explains the reasons for that Order. In short, this Court agrees with Defendants that, by signing the separation agreement, Keister waived his right to bring the instant claim for long-term disability benefits, which means that his case cannot proceed as a matter of law.

I. BACKGROUND

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410 F. Supp. 3d 244 *; 2019 U.S. Dist. LEXIS 173244 **

KIM KEISTER, Plaintiff, v. AARP BENEFITS COMMITTEE, et al., Defendants.

Subsequent History: Affirmed by Keister v. AARP Ben. Comm., 839 Fed. Appx. 559, 2021 U.S. App. LEXIS 5317, 2021 WL 1047581 (D.C. Cir., Feb. 23, 2021)

Related proceeding at Keister v. AARP, Inc., 2021 U.S. Dist. LEXIS 236451 (D.D.C., Dec. 9, 2021)

CORE TERMS

benefits, disability benefits, long-term, general release, waived, signing, employee benefits, unambiguous, disability, parties, programs, emails, entity, medical benefit, insurance plan, rights, summary judgment motion, fiduciaries, plainly, terms, pension rights, material fact, communications, affiliated, employees, courts, offers, ripe, extrinsic evidence, separate agreement