Justia ERISA Opinion Summaries

The plaintiff stopped working in November, 2005, due to a variety of ailments, and filed a disability claim in August, 2007. The claim was denied in September. The plaintiff's appeal, received in April, 2008, 11 days after the stated 180-day deadline, was denied. She filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132. A magistrate upheld the denial. The Seventh Circuit affirmed. The plaintiff failed to exhaust administrative remedies. The plan has a clear deadline; the plaintiff was not denied meaningful access to review procedures and did not allege that pursuing administrative remedies would be futile. The court rejected a "substantial compliance" argument, noting that the plaintiff did not offer an explanation for the late filing. The Plan was not required to show prejudice as a result of the delay to justify rejecting the claim. Letters sent by the plaintiff could not reasonably be construed as notice of appeal. The Plan has procedures to minimize conflicts of interest and its refusal to consider the appeal was not arbitrary.