United States District Court, D. New Jersey
THE ESTATE OF MARK JENNINGS, by Administratrix ad Prosequendum, Emily Jennings, Plaintiff,
METROPOLITAN LIFE INSURANCE COMPANY a/k/a METLIFE, Defendant.
Robert Aaron Greenberg, Esq., ARONBERG, KOUSER & PAUL, Cherry Hill, NJ, Attorney for Plaintiff.
Randi F. Knepper, Esq., MCELROY, DEUTSCH, MULVANEY & CARPENTER, LLC, Newark, NJ, Attorney for Defendant.
JEROME B. SIMANDLE, Chief District Judge.
This matter comes before the Court on the motion of Defendant Metropolitan Life Insurance Company ("Metlife") for summary judgment. [Docket Item 12.] In this action, Plaintiff Emily Jennings, Administratrix ad Prosequendum of the Estate of Mark Jennings, challenges Metlife's denial of the Estate's claim for life insurance benefits under the Delta Pilots Disability and Survivorship Trust ("the Plan") pursuant to the Employee Retirement Income Security Act of 1974. The Plan contracted with Xerox Business Services, LLC ("Xerox") to handle billing and cancellation decisions. Metlife, the Plan's claim administrator, ultimately denied the Estate's claim because Xerox cancelled Mr. Jennings' life insurance coverage, allegedly upon his written request in April, 2009, and Metlife had not received premiums for Mr. Jennings' life insurance coverage for over six months at the time of his death in December, 2009. Plaintiff contends that Mr. Jennings never cancelled his life insurance coverage and, at the time of his death, was on a special conflict military leave of absence which required his employer, Delta Air Lines, Inc. ("Delta"), to continue paying premiums on his behalf.
Metlife asserts that even if Xerox made a mistake in cancelling Mr. Jennings' life insurance coverage, Metlife had no role in the cancellation and thus cannot be responsible if it was erroneous. Accordingly, Metlife's motion requires the Court to consider whether Metlife properly denied the Estate's claim for benefits under the terms of the Plan and whether Metlife can be liable for a potential error by Xerox over two years prior to the filing of the claim for benefits. Delta and Xerox are not parties herein.
For the reasons discussed below, the Court will grant Metlife's motion for summary judgment, but does not determine the liabilities of Delta or Xerox for the alleged mistakes in cancelling the decedent's life insurance coverage in 2009.
Mark Jennings was killed by a motorist outside of his Cherry Hill, New Jersey home on December 14, 2009. (Pl. Supp. Statement of Disputed Material Facts ("Pl. SSMF") [Docket Item 15-2] ¶ 1.) At the time of his death, Delta employed Mr. Jennings as a pilot and offered benefits to its employees, including an employee welfare benefit plan entitled "Delta Pilots Disability and Survivor Trust." (Id. ¶ 2.) Metlife was the claims administrator of the Plan and responsible for paying benefits under the Plan. (Id. ¶ 3.) Xerox was the records custodian for the Plan. (Id.) Because Metlife was not the record-keeper under the Plan, Metlife did not maintain records regarding who is insured under the terms of the Plan or send bills or other pre-claim notices to Plan participants regarding their eligibility or participation in the Plan. (Def. Statement of Uncontested Material Facts ("Def. SMF") [Docket Item 12-2] ¶ 5.)
At the time of his death, Mr. Jennings was a Lieutenant Colonel enlisted with the New Jersey Air National Guard on active duty in support of Operation Noble Eagle. (Jennings Aff., Pl. Ex. B [Docket Item 15-5] ¶ 3.) As such, Mr. Jennings was on a military leave of absence from Delta from December 1, 2008 until his death on December 14, 2009. (Ex. B. to O'Dell Cert. [Docket Item 12-5] at ML0127.)
The Plan defines "ELIGIBLE CLASS(ES)" in relevant part as follows:
The following employees are eligible for coverage:
- Employees classified as pilots by Delta Air Lines and are regularly employed by Delta Air Lines.
- Pilot employees who retire from Delta Air Lines directly from active work or disability status.
- Pilot employees who become disabled and who qualify for benefits under Delta Pilots Disability and Survivorship plan.
(Def. SMF ¶ 2; see also Def. Ex. A [Docket Item 12-4] at ML0173.) The Plan identifies the date when an employee's insurance will end as follows:
DATE YOUR INSURANCE ENDS
Your insurance will end on the ...