Sign In
Events
Newsletters
Search

Close

Close Search

Cancel

SEARCH
MY LAW.COMNEW

Dunnigan v. Metropolitan Life Insurance Co.

X

Thank you for sharing!

Your article was successfully shared with the contacts you provided.
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.

Trending Stories

 
Reprints & Licensing
Mentioned in a Law.com story?

License our industry-leading legal content to extend your thought leadership and build your brand.

LEARN MORE

More From ALM

Premium Subscription

With this subscription you will receive unlimited access to high quality, online, on-demand premium content from well-respected faculty in the legal industry. This is perfect for attorneys licensed in multiple jurisdictions or for attorneys that have fulfilled their CLE requirement but need to access resourceful information for their practice areas.
View Now

Team Accounts

Our Team Account subscription service is for legal teams of four or more attorneys. Each attorney is granted unlimited access to high quality, on-demand premium content from well-respected faculty in the legal industry along with administrative access to easily manage CLE for the entire team.
View Now

Bundle Subscriptions

Gain access to some of the most knowledgeable and experienced attorneys with our 2 bundle options! Our Compliance bundles are curated by CLE Counselors and include current legal topics and challenges within the industry. Our second option allows you to build your bundle and strategically select the content that pertains to your needs. Both options are priced the same.
View Now
Go to CLE Center

New York Legal Awards (NYLA) 2023

October 05, 2023
New York, NY

The New York Law Journal honors attorneys and judges who have made a remarkable difference in the legal profession in New York.


Learn More

GlobeSt. NET LEASE Fall 2023

October 16, 2023 - October 17, 2023
Los Angeles, CA

This conference brings together the industry's most influential & knowledgeable real estate executives from the net lease sector.


Learn More

GlobeSt. Multifamily Fall 2023

October 16, 2023 - October 17, 2023
Los Angeles, CA

Join the industry's top owners, investors, developers, brokers & financiers at THE MULTIFAMILY EVENT OF THE YEAR!


Learn More
Go to Events Go to Webcasts

Finance/Corporate Trust Lawyer - CT or Remote


We are seeking a lawyer with a minimum of four years of experience in transactional work to join our well-established, nationally renowned C...


Apply Now ›

COMMERCIAL FINANCE ATTORNEY - CT OFFICES; REMOTE will be considered


We are seeking an attorney to join our commercial finance practice in either our Stamford, Hartford or New Haven offices. Candidates should ...


Apply Now ›

FINANCE & REAL ESTATE ASSOCIATES - Connecticut Preferred; Remote will be considered


Shipman & Goodwin LLP is seeking two associates to expand our national commercial real estate lending practice. Candidates should have ...


Apply Now ›
Go to Lawjobs

Chiesa Shahinian & Giantomasi

09/25/2023
New Jersey Law Journal

Prof


View Announcement ›

RIKER DANZIG SCHERER HYLAND & PERRETTI LLP

09/18/2023
New Jersey Law Journal

Riker Danzig deeply mourns the passing of our esteemed partner, dear friend and beloved colleague, Marc D'Angiolillo.


View Announcement ›

Eisenberg, Rothweiler, et.al

09/12/2023
TLI Web

Eisenberg Rothweiler


View Announcement ›
Go to Professional Announcements

Legal Newswire

Rethink Continuing Legal Education with Lawline’s AI-Powered ‘Learning Assistant...
Leading Law Firms Establish First-of-its-Kind Consortium to Train Law Firms on G...
Prominent Black Attorney, Zulu Ali, Wins Landmark Case in U.S. Federal Court of ...
The Katz Law Firm P.C. Launches in Illinois and Wisconsin
Submit a press release