Sumpter argued he was entitled to an early-payout long-term disability (LTD) benefit under General Motors’ 1992 plan, even though GM eliminated that benefit in 1994 and Delphi — the GM spinoff whose plan governed when he actually became disabled — never restored it. He sued Delphi Automotive Systems (Holding), Inc., the Delphi Automotive Systems Life & Disability Benefits Program, MetLife Group, Inc., and Metropolitan Life Insurance Company, and the Seventh Circuit affirmed summary judgment for the defendants, calling the lawsuit frivolous and holding that ERISA doesn’t allow a court to read a benefit into a plan that its terms never provided, regardless of whether Sumpter was given plan summaries.
- Case
- Sumpter v. MetLife
- Court
- United States Court of Appeals for the Seventh Circuit, affirming the United States District Court for the Southern District of Indiana
- Decided
- April 18, 2017 (Seventh Circuit); March 18, 2014 (district court)
- Claim type
- Long-Term Disability (ERISA) — early-payout benefit eligibility, not a medical disability dispute
- Insurer
- Metropolitan Life Insurance Company and MetLife Group, Inc., as Plan Claims Administrator
- Employer
- General Motors, later Delphi Automotive Systems (Holding), Inc. (post-spinoff)
- Occupation
- Electrical Engineer
- Conditions
- Not applicable — case turned on plan-benefit eligibility, not medical evidence
Sumpter had worked as an electrical engineer, first for General Motors and later for Delphi following GM’s spinoff of the division. His disability arose while covered under Delphi’s plan, which is why the case turned on Delphi’s 2000 plan terms rather than the earlier GM plan he’d been covered under years before.
Procedural History: Sumpter then brought this ERISA suit in the Southern District of Indiana against DPH, Delphi’s Disability Benefits Program Plan, and MetLife. In granting summary judgment for MetLife, the district court reasoned that when Sumpter became disabled, Delphi’s plan did not provide the benefit he sought and that he was not entitled to equitable relief.
Issues: Whether there is insurance coverage in this claim.
Holdings: The problem for Sumpter is on the merits: his lawsuit is frivolous because MetLife has no obligation to pay the benefit he seeks. Sumpter doesn’t seriously dispute that GM eliminated the early-payout benefit from its plan in 1994 and that Delphi didn’t include a similar benefit in its 2000 plan. Even so, Sumpter argues he is entitled to the early-payout benefit under GM’s 1992 plan because GM (and later Delphi) didn’t give him plan summaries. But whether or not that allegation is true, section 1132(a)(1)(B) does not authorize a court to “reform” a plan by reading into it a benefit not provided by the plan’s terms.
Noteworthy Court Comments: “This litigation represents the latest effort by James Sumpter to receive a disability benefit that his former employer, Delphi Automotive Systems, did not offer as part of its employee welfare benefits plan when he became disabled. He now seeks recovery against the plan’s claims administrator, Metropolitan Life Insurance Company, on the grounds that it wrongly denied him benefits and breached fiduciary duties arising under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. §§ 1001–1461. Sumpter’s contentions are frivolous, so we affirm the district court’s grant of summary judgment for MetLife.”
Here is a PDF copy of the decision: Sumpter v. MetLife
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