Taller v. MetLife Group Inc.
- Paul Engelmayer
- 1:22-cv-01915
- U.S. District Court · Southern District of New York
- 3
In Taller v. MetLife Group Inc., Judge Engelmayer granted dismissal because federal benefits law preempted the claims, allowing Taller to amend.
Samuel Taller and the defendants—MetLife Group Inc., Metropolitan Life Insurance Company, and MetLife, Inc. Taller’s complaint was dismissed without prejudice to amending it to allege non-preempted claims.
What happened
Samuel Taller, representing himself, sued MetLife Group Inc., Metropolitan Life Insurance Company, and MetLife, Inc. for damages and an order requiring the defendants to act. The defendants asked the court to dismiss his claims.
Magistrate Judge Sarah Netburn recommended dismissing the claims because the Employee Retirement Income Security Act, a federal benefits law, replaced or blocked the legal theories Taller used. No party objected to that recommendation, so the court reviewed it for obvious error and found none.
Judge Engelmayer adopted the recommendation, granted the defendants’ motion to dismiss, and dismissed the complaint without prejudice to Taller amending it to allege claims not blocked by that law.
The detailed version
- Taller v. MetLife Group Inc. · No. 1:22-cv-01915
- Paul Engelmayer
- Feb. 1, 2023
Background
Samuel Taller, proceeding without a lawyer, sought damages and injunctive relief against MetLife Group Inc., Metropolitan Life Insurance Company, and MetLife, Inc. The defendants moved to dismiss Taller’s claims. The court referred that motion to Magistrate Judge Sarah Netburn for a Report and Recommendation, which is a magistrate judge’s proposed ruling for the district judge to review.
Report and Recommendation
On January 3, 2023, Judge Netburn recommended dismissing Taller’s claims because they were preempted under section 502(a)(1)(B) of the Employee Retirement Income Security Act of 1974 (ERISA), codified at 29 U.S.C. § 1132(a). No party filed objections.
Because there were no objections, the district court reviewed the recommendation for clear error, meaning an obvious mistake on the face of the record. The court found no such error and adopted the Report and Recommendation in its entirety.
Ruling
The court accepted and adopted Judge Netburn’s January 3, 2023 Report and Recommendation, granted the defendants’ motion to dismiss, and dismissed the complaint without prejudice to Taller amending it to allege proper, non-preempted claims. The court also stated that the parties’ failure to object waived appellate review of those objections. The Clerk of Court was directed to terminate the motion and mail Taller a copy of the decision.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.