White v. Anthem Life Insurance Company
- Haywood Gilliam
- 4:20-cv-03591
- U.S. District Court · Northern District of California
- 4
In White v. Anthem Life Insurance Company, Judge Gilliam granted Anthem’s motion to dismiss because White missed the 180-day appeal deadline under the employee-benefits law.
Patricia White and Anthem Life Insurance Company; White’s ERISA claim for continued long-term disability benefits was dismissed, and the case was closed.
What happened
In White v. Anthem Life Insurance Company, Patricia White sought continued long-term disability benefits under an employee-benefits plan governed by the Employee Retirement Income Security Act. Anthem stopped paying benefits in 2014 and denied White’s request for continued benefits, telling her that any appeal had to be filed within 180 days.
White did not appeal within that period. She later sent Anthem a letter in February 2020 asking it to review the termination, but the court ruled that the letter came too late and did not satisfy the plan’s appeal requirement. White argued that the letter was an effective appeal; the court disagreed and did not address Anthem’s other arguments.
Judge Haywood S. Gilliam, Jr. granted Anthem’s motion to dismiss White’s first amended complaint without leave to amend and directed the clerk to close the case.
The detailed version
- White v. Anthem Life Insurance Company · No. 4:20-cv-03591
- Haywood Gilliam
- Feb. 2, 2021
Background
Patricia White was a participant and covered beneficiary under an employer welfare plan governed by the Employee Retirement Income Security Act (ERISA) and issued by Anthem Life Insurance Company. Anthem approved White’s long-term disability benefits in 2012, stopped paying them on April 2, 2014, and denied her request for continued benefits by letter dated October 1, 2014. The letter explained that an appeal had to be filed within 180 days after White received the denial.
In an earlier round of this dispute, the court granted Anthem summary judgment because White had not exhausted the plan’s internal appeal procedures before seeking judicial review. The Ninth Circuit affirmed that ruling. While that appeal was pending, White sent Anthem a February 20, 2020 letter asking it to review the termination of her benefits. Anthem responded that she was not eligible for an appeal, denied her request for benefits after April 2, 2014, and stated that her file remained closed. White then filed this action, and the court considered Anthem’s motion to dismiss her first amended complaint.
Parties’ Arguments
Anthem argued that the allegations showed White had failed to timely exhaust her administrative remedies. In this context, exhaustion meant using the plan’s required internal review process before bringing an ERISA benefits claim in federal court.
White argued that her February 2020 letter was an unambiguous and complete appeal that satisfied the exhaustion requirement. She also argued that comments made during an earlier summary-judgment hearing suggested the court had not decided whether the plan’s 180-day deadline applied.
Court’s Analysis
The court applied Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. It held that the plan required exhaustion as a mandatory prerequisite to suit and that the October 2014 denial letter adequately notified White that her claim had been denied. That notice triggered the 180-day appeal deadline.
The February 2020 letter was outside the 180-day period and therefore did not cure White’s failure to file a timely appeal. The court also rejected White’s interpretation of the earlier hearing, explaining that it conflicted with the court’s written summary-judgment order and the Ninth Circuit’s affirmance. Because this threshold issue resolved the case, the court did not address Anthem’s other arguments.
Disposition
The court granted Anthem’s motion to dismiss White’s first amended complaint without leave to amend, finding that the pleading could not be cured by alleging additional facts. The court directed the clerk to close the case.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.