In Leonard v. MetLife Insurance Company, the Ninth Circuit court of appeals upheld the California district court’s dismissal of plaintiff’s ERISA lawsuit against MetLife when she failed to exhaust her administrative remedies or prove there was any applicable exception to excuse her from filing an administrative appeal. The court did not discuss her case or consider the merits of her disability claim, but focused on the proper procedure claimants must file when seeking disability benefits.

According to the appellate court, “Although not specifically mandated by ERISA, this court requires an ERISA plaintiff to ‘avail herself of a plan’s own internal review procedures before bringing suit in federal court.'” There are exceptions to this rule when a plaintiff can prove “exhausting administrative remedies would be futile or a plan does not establish or follow claims procedures as required by ERISA.”

Plaintiff Did Not Prove Administrative Appeal Would Have Been Futile

Plaintiff claimed an appeal would have been futile, but failed to prove her case. In fact, this same plaintiff had previously had a claims determination by MetLife reversed when she followed the correct administrative appeal procedures. Contrary to her claim that no new information would have been required for her appeal, this claim ignored the change in the disabled definition that occurred during the evaluation of her case and that MetLife did need updated medical information that she could have provided if she had followed the required administrative appeals process. Since she did not provide evidence to support her claim that MetLife’s administrative appeals process was “demonstrably doomed to fail,” she did not meet her burden in proving she was excused from the exhaustion requirement.

Plaintiff Failed to Show MetLife’s Claims Procedure Violated ERISA

The plaintiff simply failed to provide any proof to support her claim that MetLife’s claims procedure violated ERISA. MetLife’s letter denying her benefits “outlined its reasoning” for denying her benefits. Her assertion that MetLife’s failure to consult with a vocational expert before denying her claim violated ERISA requirements was not supported by any evidence or persuasive authority.

This case was not handled by our office, but we feel it is instructive for those who may be considering an ERISA lawsuit, but have not yet exhausted their administrative remedies. If you need assistance with your claim for disability benefits, contact one of our attorneys for a free consultation.