- Lewis v. Aetna Ins. Agency Inc.
- December 20, 2010 | Authors: Kathryn M. Almar; Arthur N. Lerner
- Law Firm: Crowell & Moring LLP - Washington Office
In considering claims brought by a husband and wife ("Plaintiffs") against their employer-sponsored health plan and the plan fiduciary, a federal judge in Illinois dismissed all of the Plaintiffs' claims as duplicative and moot, among other reasons.
Plaintiffs Annie and Herbert Lewis were insured through a plan offered by Herbert's employer, Sherwin-Williams Co. Aetna Insurance Agency, Inc. ("Aetna") served as the plan fiduciary and was responsible for reviewing claims.
Following a horse-riding accident, Annie Lewis amassed medical bills totaling $38,165.92 for which she sought benefits under Plaintiffs' health plan. Aetna denied benefits, citing in part a pre-existing condition, and thereafter Annie's medical providers won judgments against her. The Plaintiffs subsequently brought claims against Aetna in state court, and the matter was removed to federal court on Aetna's motion based on ERISA preemption. The Plaintiffs later added Sherwin-Williams Co. as a co-defendant.
A federal judge in the U.S. District Court for the Southern District of Illinois concluded that two of the Plaintiffs' claims -- for arbitrary and capricious actions by Aetna and violation of ERISA Section 502(a)(1)(B) by the plan -- were duplicative since both alleged essentially the same thing. The court found that the only difference between these two claims was that one was against Aetna and the other was against the Plaintiffs' health plan. The complaint made clear that both counts were civil actions for violations of ERISA Section 502(a)(1)(B). As a result, the court dismissed the Plaintiffs' claim against Aetna for arbitrary and capricious conduct as duplicative.
Turning to the Section 502(a)(1)(B) claim against the health plan, the court found that, while there was evidence that Aetna did not process the claims in a timely fashion, such untimeliness did not impute additional liability to the plan in an action for benefits. The court pointed out that ERISA Section 502(a)(1)(B) "does not provide for compensatory damages, money damages, or extracontractual relief." Therefore, the court found that no genuine issue of material fact existed with respect to the civil judgments against the Plaintiffs. Furthermore, because the plan had already provided the relief allowable to the Plaintiffs, their ERISA Section 502(a)(1)(B) claim was moot.
The court dismissed the remaining counts asserted by the Plaintiffs for various reasons, including that Herbert Lewis did not have standing to bring suit under ERISA. As a result of its findings, the court almost entirely granted the defendants' motion for summary judgment, and dismissed the remaining count as moot.