Kayser v. Guardian Life Insurance Company of America

Background

Bridget Kayser sued Guardian Life Insurance Company of America and Berkshire Life Insurance Company of America over the denial of her application for long-term disability benefits. The opinion addresses Guardian’s motion for summary judgment, which asks the court to rule that no genuine factual dispute requires a trial. The motion concerned only the claims against Guardian.

The benefits plan covered employees of Tifco Industries and gave Guardian discretionary authority to decide eligibility for benefits and interpret the plan. The plan required claimants to provide proof of loss and stated that an employee could not bring a legal action more than three years after filing proof of loss.

Kayser initially reported tinnitus and later asserted that anxiety and shoulder pain also affected her ability to work. The parties disputed some details about when Kayser was cleared to return to work and whether Guardian properly considered her additional conditions. Guardian denied her long-term disability application in 2013, stating that she had not submitted sufficient proof of loss. Guardian later denied her appeal, stating that she had not provided medical evidence showing that she could not perform the major duties of her occupation and had not shown that she remained under regular medical care during the plan’s 90-day elimination period.

State-law claims

Kayser brought breach-of-contract and fraud claims against Guardian. Guardian argued that the Employee Retirement Income Security Act (ERISA) preempted those claims, meaning that ERISA displaced the state-law claims because they concerned benefits under an employee benefit plan. Kayser conceded that the state claims against Guardian were preempted. The court therefore dismissed her breach-of-contract and fraud claims against Guardian.

ERISA fiduciary-duty claim

Guardian argued that Kayser’s ERISA claims were barred by the applicable time limits. Kayser relied on ERISA’s extended six-year period for claims involving fraud or concealment. The court held that Kayser’s complaint pleaded enough facts to put Guardian on notice that she was pursuing a claim for breach of fiduciary duty, even though the complaint did not expressly use that claim’s name.

The court found a genuine dispute of material fact about whether Guardian breached a fiduciary duty by withholding important information or providing incorrect information. The record included evidence that Guardian allegedly failed to provide requested documents and repeatedly sent documents to incorrect contacts. The court said a jury could plausibly find that this conduct induced Kayser not to provide information that might have secured benefits under the plan.

The court emphasized that most of Kayser’s complaints concerned Guardian’s review of her benefits claim, rather than fraud or concealment connected to a fiduciary-duty breach. It denied summary judgment only as to the ERISA fiduciary-duty claim based on alleged fraud or concealment.

ERISA benefits claim and disposition

To the extent Kayser sought judicial review of Guardian’s denial of benefits under ERISA, the court dismissed that claim as barred by the plan’s three-year limitations period. The court’s conclusion was that the breach-of-fiduciary-duty claim remained, while the breach-of-contract claim, fraud claim, and ERISA denial-of-benefits claim were dismissed.

The court granted in part and denied in part Guardian’s summary-judgment motion. It stated that Kayser’s only remaining claim against Guardian was the ERISA breach-of-fiduciary-duty claim. The opinion does not state a dismissal qualifier such as “with prejudice” or “without prejudice.”