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United States Court of Appeals for the Eighth Circuit
March 16, 2022, Submitted; May 6, 2022, Filed
BENTON, Circuit Judge.
Corey Skelton sued Reliance Standard Life Insurance Company for mishandling his wife's enrollment for supplemental life insurance and then declaring her ineligible for it after she died. The district court1 granted him summary judgment, finding the company violated the Employee Retirement Income Security Act of 1974, 29 U.S.C. §§ 1001 et seq. Having jurisdiction under 28 U.S.C. § 1291, this Court affirms.
Corey Skelton was married to Beth M. Skelton ("Skelton"), a corporate group sales manager at Davidson Hotels LLC.
Davidson operated a welfare benefits plan ("Plan") that provided dental, health, life and long-term disability [*2] benefits for employees. Davidson's documents identified it as the "Plan Administrator" with general "discretionary authority to interpret the Plan," and determine eligibility for coverage and eligibility for claims.
Davidson entered a policy contract ("Policy") with Reliance Standard Life Insurance Company to provide life insurance for the Plan. Reliance "serve[d] as the claims review fiduciary with respect to the [life] insurance policy and the Plan." The Policy granted it "final and binding" "discretionary authority to interpret the Plan . . . and to determine eligibility for benefits."
Reliance also had sole discretion to determine eligibility for supplemental life insurance under various circumstances, including when an employee sought it more than 31 days after starting employment. In this circumstance, the employee was required to submit an Evidence of Insurability ("EOI"), demonstrating "proof of good health." Insurance would not become effective until Reliance "approve[d] [that] required proof of good health."
However, if an applicant for supplemental life insurance was changing coverage amounts within 31 days of "a life event change (such as marriage, birth, or specific changes [*3] in employment status)," then the applicant was not required to submit an EOI and receive Reliance's approval.
Davidson collected premiums from employees and remitted them to Reliance in one monthly check for all the premiums due, along with a worksheet listing only the total number of employees insured. This is called "bulk billing." Reliance's system did not collect information that would allow it to assess whether Davidson sent mistakenly billed premiums to Reliance.
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
2022 U.S. App. LEXIS 12238 *; __ F.4th __; 2022 WL 1434778
Corey Skelton, individually and as Trustee for the next of kin of Decedent Beth Michelle Skelton, Plaintiff - Appellee v. Radisson Hotel Bloomington; Water Park of America, Defendants, Reliance Standard Life Insurance Company, a Member of the Tokio Marine Group, Defendant - Appellant, Marc L. Messina, Defendant; Department of Labor, Amicus on Behalf of Appellee(s)
Prior History: [*1] Appeal from United States District Court for the District of Minnesota.
premiums, fiduciary, enrollment, eligibility, supplemental, insurer, life insurance, employees, coverage, benefits, fiduciary duty, district court, good health, effective, determine eligibility, ineligible, breached, remitted, amounts, custody, listing, monthly, discretionary authority, summary judgment, duty of loyalty, disability, documents, stepson, entity
Civil Procedure, Appeals, Standards of Review, De Novo Review, Pensions & Benefits Law, Judicial Review, De Novo Standard of Review, Summary Judgment Review, Standards of Review, Civil Litigation, Causes of Action, Breach of Fiduciary Duty, Remedies, Damages, Extracontractual Damages, Suits to Recover Plan Benefits, Business & Corporate Compliance, ERISA, Fiduciaries, Named Fiduciary Appointment & Obligations, Delegation of Duties, Fiduciary Responsibilities, Duty of Prudence, Duty of Loyalty, Governments, Courts, Common Law, Summary Judgment, Entitlement as Matter of Law, Genuine Disputes, Evidence, Types of Evidence, Circumstantial Evidence, Inferences & Presumptions, Inferences, Business & Corporate Law, Agency Relationships, Fiduciary Duties