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Dunnigan v. Metropolitan Life Insurance Co.

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Argued: December 20, 2000

Appeal from the judgment of the United States District Court for the Southern District of New York (Scheindlin, J.) dismissing complaint for failure to state a claim. The Court of Appeals (Leval, J.) vacates the judgment.

This is an appeal by the plaintiff, Helen Dunnigan, the beneficiary of a long-term disability insurance policy issued by defendant Metropolitan Life Insurance Company (MetLife), from the dismissal of her complaint by the United States District Court for the Southern District of New York (Scheindlin, J.). Plaintiff’s complaint asserted a claim, personally and on the behalf of all other similarly situated disabled participants in MetLife disability plans, pursuant to the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. � 1001 et seq., to recover interest on benefits paid subsequent to the date when the participant was entitled to receive such payments. MetLife moved to dismiss the complaint, arguing that independent actions for interest on delayed benefit payments cannot be maintained under ERISA where benefits are awarded after internal administrative review and not through litigation. The district court rejected MetLife’s contentions, concluding that the language and policy of ERISA, taken together with common law contract principles, can in some instances support an action to recover interest on delayed benefit payments. Under the district court’s view, however, an essential element of such a claim is bad faith on the part of the insurer. Because the complaint did not allege bad faith on MetLife’s part, the court found that it failed to assert a claim upon which relief could be granted. The court denied the application for class certification and dismissed the complaint without prejudice to plaintiff’s reinstating a new suit.

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