Benson v. Tiffany & Co.

Background

Maryanne Benson sued Tiffany & Co., Tiffany & Co. Global Human Resources, Benefits, the Tiffany and Company Medical Benefit Plan as amended effective April 1, 1995, and a summary plan description identified in the caption. She sought reimbursement for $26,716 in dental work and physical therapy following serious mouth, jaw, and tooth injuries from an August 16, 2014 bicycle accident. Medicare and Tiffany-related benefit plans paid some expenses, but Benson alleged that her reimbursement claim was denied.

Benson brought claims under Sections 502(a)(1)(B) and 502(a)(3) of the Employee Retirement Income Security Act. The first provision allows a plan participant to seek benefits allegedly owed under a plan. The second allows a participant to seek certain equitable relief for violations of the law or plan terms. Benson also sought attorneys’ fees.

Benson submitted her dental claim to UnitedHealthcare on May 1, 2018. UnitedHealthcare denied the claim and, on November 9, 2018, denied her first appeal while explaining that additional information was needed about the injured teeth, the injuries, and her initial medical treatment. The denial letter instructed her to request a second-level review within 60 days. Benson submitted that second appeal 66 days after the first denial. UnitedHealthcare denied it as untimely.

Motion to Dismiss

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint plausibly states a claim for relief. They argued that Benson had not completed the benefit plan’s required administrative appeals before suing, that her fiduciary-duty claim was duplicative of her benefits claim, and that her attorneys’ fees claims could not remain after dismissal of the other claims. In the alternative, they moved to strike her jury demand if any claim survived.

The court concluded that the 2017 benefit plan governed the dispute. It reasoned that the differences between the older and newer plan documents affected the appeals process rather than reducing Benson’s substantive benefits. The court also found that the 2014 summary plan description recognized a second appeal and that UnitedHealthcare’s first denial clearly stated the 60-day deadline.

Rulings

The court held that Benson failed to plead exhaustion of the required administrative remedies for her benefits claim under Section 502(a)(1)(B). It found the 60-day deadline reasonable and enforceable and held that the first denial gave adequate notice of the second-level appeal requirement. The court rejected Benson’s arguments that further review would have been futile or that equitable tolling should apply. It found that administrative inconvenience, dissatisfaction with UnitedHealthcare’s handling of the claim, and concerns about the reviewer’s specialty did not excuse the late appeal.

The court also dismissed Benson’s Section 502(a)(3) fiduciary-duty claim. Although that provision can support equitable relief, Benson sought money equal to the denied benefits, plus interest and prejudgment interest. The court treated that request as duplicative of her benefits claim and found that she identified no separate injunction or other equitable remedy.

The court dismissed Benson’s attorneys’ fees claims because she no longer had a surviving claim and therefore could not show the required degree of success. The court granted the defendants’ motion to dismiss, denied the motion to strike the jury demand as moot, and dismissed the amended complaint with prejudice. It also held that further amendment would be futile and closed the case.