Summary
The United States District Court for the Southern District of Texas grants Prudential Insurance Company of America’s motion for judgment on the pleadings, construed as a motion for summary judgment, in an ERISA disability-benefits dispute. The court holds that Sherri Ellis-Young failed to exhaust the plan’s administrative remedies because her letters expressed only an intent to appeal and she did not submit a substantive appeal within the applicable 180-day deadline. The court declines to excuse the exhaustion requirement and enters final judgment separately.
Topics
Practice areas
Questions Presented
- Whether Ellis-Young exhausted the plan's administrative appeal procedures by sending letters stating an intent to appeal and requesting her claim file.
- Whether the administrative-exhaustion requirement should be excused or Prudential should be estopped from enforcing it.
- Whether Prudential was entitled to judgment after the court construed its motion for judgment on the pleadings as a motion for summary judgment.
Holdings
- Ellis-Young did not exhaust her administrative remedies because her letters expressed only an intent to appeal and requested information needed to prepare a future appeal; she did not submit a timely substantive appeal within the plan's 180-day deadline.
- The court declined to excuse exhaustion because Prudential did not mislead Ellis-Young, notified her of the 180-day deadline, provided the claim file within the deadline period, and had no valid appeal on which it was required to rule.
- Because the parties did not identify additional documents needed to resolve exhaustion, the court construed Prudential's motion for judgment on the pleadings as a motion for summary judgment under Rule 12(d).
Key quotations
“Failure to exhaust a plan’s internal appellate procedures can result in dismissal of a plaintiff’s claim.” (at 1)
“On this record, Ellis-Young did not exhaust her administrative remedies because she failed to appeal timely Prudential’s denial of her disability benefits.” (at 3)
“This case has all the material facts that led to dismissal in Holmes and Swanson.” (at 5)
Factual background
Ellis-Young received long-term disability benefits under an employer-sponsored disability plan administered by Prudential from May 12, 2022, through January 31, 2023. Prudential terminated her benefits effective February 3, 2023, and advised her that she had 180 days to appeal. Ellis-Young and her counsel sent letters expressing an intent to appeal and requesting the claim file, but they did not submit substantive arguments or supporting evidence until September 2025, long after the appeal deadline.
Procedural history
Ellis-Young filed an ERISA action challenging Prudential's termination of her long-term disability benefits. Prudential answered and moved for judgment on the pleadings. The court construed the motion as a summary-judgment motion, determined that the administrative record did not require additional documents for resolution of exhaustion, and granted Prudential's motion; a final judgment was to be entered separately.