Facts

Patricia White filed suit against Anthem Life Insurance Co., Merced Systems Inc., and Merced Systems Health and Welfare Plan, in relation to Anthem's denial of her continuing long-term disability benefits. White participated in Merced Systems' employee welfare plan governed by ERISA and issued by Anthem. The Plan provided benefits for qualifying long-term injuries and illnesses, and when submitting a claim for benefits, a participant must include a written proof of disability or loss in which a physician provided information about the participant's medical conditions. Upon denial of a benefits claim, a participant may request appeal in writing within 180 days of receipt of notice of denial. The Plan also provided legal action could not be taken over three years after written proof of loss was required.

White voluntarily dismissed Merced Systems and Merced Systems Health and Welfare Plan, leaving Anthem as the sole defendant.

PLAINTIFF'S CONTENTIONS: White contended Anthem approved her long-term disability benefits claim on Oct. 11, 2012, to be payable on April 2, 2012 and expire April 2, 2014, after which she would have to prove she was unable to perform any occupation for which she was qualified, in order to keep receiving long-term disability benefits. White alleged she made a request for continued benefits in March 2014, and Anthem denied her request on Oct. 1, 2014. White conceded she did not appeal Anthem's decision, but she filed this action seeking review of Anthem's denial of continuing long-term disability benefits. White alleged that she sent a letter to Anthem on Sept. 25, 2014, requesting immediate notification of the status of her benefits claim, and asserting that she reserved her right to appeal if Anthem denied her claim. White asserted causes of action for benefits due under the Plan pursuant to ERISA Section 502(a)(1)(B), breach of fiduciary duties under ERISA, and statutory penalties under ERISA Section 502(a)(1)(A).

DEFENDANTS' CONTENTIONS: Anthem contended White failed to exhaust her administrative remedies and Anthem was entitled to summary judgment.

Result

The court granted Anthem's motion for summary judgment. The court concluded that the Plan required exhaustion of administrative remedies as a mandatory prerequisite to initiating legal action, and the Plan made clear that to have a denied claim reconsidered, the participant must appeal within 180 days of receiving notice of Anthem's denial. The court found Anthem fully informed White of these obligations and the evidence established White was required to exhaust her administrative remedies before filing suit. The court concluded White failed to exhaust her administrative remedies because her Sept. 25, 2014 letter did not constitute an appeal, Anthem's correspondence with her was not legally deficient, and it was undisputed that she did not file an appeal as required to exhaust her administrative remedies.