In late December 2010, an employee of the United States Postal Service froze to death outside the bulk mail center where he worked. His adult children filed for life and accidental death benefits under a group policy issued by Metropolitan Life Insurance Company (“MetLife”). In March 2011, MetLife denied the claim, reportedly contending that the employee’s heart disease was a pre-existing condition. In October 2012, the children appealed, and nearly five years later, in July 2017, MetLife issued a final decision, sustaining its denial.
In March 2018, the children filed a lawsuit in state court, which was subsequently removed by MetLife to federal court. MetLife responded with a pre-answer motion to dismiss on statute of limitations grounds, contending that regardless of the merits of allegations in the complaint, the lawsuit was brought well outside of the policy’s two-year limitations period, measured from when MetLife denied the claim (i.e., March 2011).
Denying the motion, the district court noted that MetLife grounded its argument in a provision of the policy, a document that was “outside of the pleadings,” and which the court could not consider on a pre-answer motion to dismiss (except in certain circumstances not present).
McCauley v. Metropolitan Life Ins. Co. (D. N.J. Jan. 8, 2019)
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Evan S. Schwartz
Founder of Schwartz, Conroy & Hack
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