Summary
The Ninth Circuit held that an ERISA disability-benefits claimant's claims were deemed exhausted because the plan failed to decide his administrative appeal within the applicable regulatory deadline. The court deferred to the Secretary of Labor's interpretation that the quarterly-meeting timing rule for disability claims is limited to multiemployer plans, reversed the district court's judgment, and remanded.
Topics
Practice areas
Questions Presented
- Whether the district court's dismissal without prejudice for failure to exhaust administrative remedies constituted a final appealable judgment under 28 U.S.C. § 1291.
- Whether Barboza's ERISA disability-benefits claims should be deemed exhausted because the Plan failed to resolve his administrative appeal within the time limits prescribed by 29 C.F.R. § 2560.503-1(i).
- Whether a non-multiemployer plan with a committee or board that meets quarterly may use the quarterly meeting rule to resolve disability-benefits claims.
Holdings
- A dismissal without prejudice for failure to exhaust administrative remedies is a final appealable judgment when the district court terminated the action in its entirety, entered judgment for the defendant, and gave no indication that the claimant could restart or continue the administrative process.
- Whether an ERISA claim should be deemed exhausted under 29 C.F.R. § 2560.503-1(l) is a question of law reviewed de novo, rather than a discretionary exception reviewed for abuse of discretion.
- When an ERISA plan fails to establish or follow reasonable claims procedures consistent with ERISA and fails to decide a disability-benefits appeal within the applicable regulatory period, the claimant's claims are deemed exhausted under 29 C.F.R. § 2560.503-1(l).
- The quarterly meeting rule is restricted to multiemployer plans when a claimant seeks review of disability-benefits claims; a non-multiemployer plan may not use quarterly meetings to avoid the disability-claim decision deadlines.
Key quotations
“Accordingly, the Plan was required to render a decision within ninety days of Barboza's administrative appeal. Inasmuch as the Plan failed to do so, Barboza's claims must be deemed exhausted.” (1080)
Factual background
Barboza sought long-term disability benefits under the defendants' ERISA plan. Although the parties agreed that he was entitled to an award of benefits, they disputed whether the Plan could offset the award based on payments that Barboza received or could have received under state law. Barboza did not complete all available administrative remedies, and the Plan failed to resolve his administrative appeal within the regulatory time limits.
Procedural history
Barboza sued the Plan in March 2008 for refusing to pay long-term disability benefits. The parties later agreed that Barboza was entitled to benefits but disputed whether the Plan could offset those benefits based on state-law payments. The district court dismissed the claims without prejudice and entered judgment for the Plan after finding that Barboza had failed to exhaust available administrative remedies. The Ninth Circuit held that the dismissal was a final appealable judgment, reviewed the exhaustion issue de novo, reversed, and remanded.
Remand instructions
Further proceedings consistent with the holding that Barboza's claims were deemed exhausted because the Plan failed to decide his administrative appeal within the applicable regulatory period. Barboza was awarded his costs on appeal.