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Court Holds that Benefit Denial Notices Must Include Time Limits for Judicial Review

In the case of Moyer v. Metropolitan Life Ins. Co., the U.S. Court of Appeals for the Sixth Circuit held that a notice of benefit denial under ERISA must include not only a statement of the claimant?ÇÖs right to judicial review of the benefit denial, but also any associated time limits for filing a claim for judicial review. Moyer was a participant in an employer-sponsored long-term disability plan that was subject to ERISA (the ?Ç£Plan?Ç¥). MetLife was the designated claims fiduciary under the Plan. MetLife denied Moyer?ÇÖs claim for benefits and his subsequent internal appeal of that denial. Nearly four years later, Moyer sued MetLife for the denied benefits under Section 502 of ERISA. The Plan document specified a three-year limitations period for filing such a lawsuit, but neither MetLife?ÇÖs benefit denial notice to Moyer nor the Plan?ÇÖs summary plan description (?Ç£SPD?Ç¥) included any such limitations period. The district court… Continue Reading

September 2014
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