Case Name: James B. Sumpter v. Metropolitan Life Insurance Company
Court: U.S. Court of Appeals for the Seventh Circuit.
Date of Decision: April 18, 2017.
Type of Claim: Long Term Disability.
Insurance Company: Metropolitan Life Insurance Company, aka MetLife for short.
Claimant’s Employer: General Motors.
Claimant’s Occupation / Job Position: Electrical Engineer.
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 seeks and that he is 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.”