Bailey v. United of Omaha Life Insurance Company

CourtDistrict Court, S.D. Ohio
DecidedMarch 22, 2023
Docket2:21-cv-05164
StatusUnknown

This text of Bailey v. United of Omaha Life Insurance Company (Bailey v. United of Omaha Life Insurance Company) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bailey v. United of Omaha Life Insurance Company, (S.D. Ohio 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

GRIFFIN BAILEY, Case No. 2:21-cv-5164 Plaintiff, v. Judge Graham

UNITED OF OMAHA LIFE Magistrate Judge Jolson INSURANCE COMPANY, et al.,

Defendants.

OPINION AND ORDER

Plaintiff Griffin Bailey brings this action under the Employee Retirement Income Security Act of 1974 (“ERISA”) against Defendants United of Omaha Life Insurance Company (“United”) and Hirschvogel Incorporated (“Hirschvogel”). Plaintiff claims United and Hirschvogel violated provisions of ERISA by denying his claim for life insurance benefits from policies belonging to his late father, Adam Bailey. This matter is before the Court on Hirschvogel’s motion to dismiss, Doc. 7. For the reasons set forth below, the Court denies Hirschvogel’s motion. I. Background A. Factual Background Adam Bailey was an employee of Hirschvogel from September 16, 2016 to September 24, 2019. Compl. at ¶¶ 12-13. During his employment, he obtained two life insurance policies (the “Policies”) taken out as part of an employee welfare benefit plan established by Hirschvogel under the provisions of ERISA. Id. at ¶ 1, 14-15. Plaintiff is the sole beneficiary of the proceeds from the Policies. Id. at ¶ 17. Adam Bailey died in a traffic accident on November 6, 2019, less than two months after terminating his employment with Hirschvogel. Id. at ¶ 18. Shortly after Adam Bailey’s death, Hirschvogel discovered that a glitch in their system caused United to not be informed when several employees, including Adam Bailey, terminated their employment. Id. at ¶¶ 19-20. As a result,

Adam Bailey’s life insurance was not canceled at the end of his employment, the premiums continued to be paid, and he was not notified of the possibility that his life insurance would be canceled. Id. at ¶ 22, 28. Upon discovering the issue, Hirschvogel retroactively terminated Adam Bailey’s life insurance effective September 30, 2019. Id. at ¶ 21. B. Procedural Background Plaintiff submitted a claim for life insurance benefits to United and Hirschvogel. Id. at ¶ 25. United reviewed the claim and ultimately denied it, explaining that the Policies were terminated on September 30, 2019, prior to Adam Bailey’s death. Id. at ¶ 30. Plaintiff then appealed United’s decision. Id. at ¶ 32. United denied Plaintiff’s appeal. Id. at ¶ 38. Plaintiff filed a two-count complaint on October 29, 2021. Id. Count I is a claim against

United for benefits under ERISA, 29 U.S.C. § 1132. Id. at ¶¶ 44-48. Count II is a claim for “other remedies.” Specifically, Plaintiff alleges that United and Hirschvogel “violated the provisions of ERISA, including breach of their fiduciary duty, in their handling of Griffin Bailey’s claim for life insurance benefits, administration of those benefits, and denial of those benefits to Plaintiff.” Id. at ¶ 50. Before the Court is Hirschvogel’s motion to dismiss Count II of Plaintiff’s Complaint. Doc. 7. II. Standard of Review To survive a motion to dismiss under Rule 12(b)(6), a claim must “contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal quotation and citation omitted). The plausibility standard “calls

for enough fact to raise a reasonable expectation that discovery will reveal evidence of [unlawful conduct].” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 556 (2007). A complaint’s “[f]actual allegations must be enough to raise a right to relief above the speculative level, on the assumption that all the allegations in the complaint are true (even if doubtful in fact).” Id. at 555 (internal citations omitted). III. Discussion A. Legal Basis for Claim The first step in determining whether Plaintiff has asserted a claim upon which relief can be granted is to discern the legal basis for Count II. Plaintiff, in his response brief, dodges the issue by asserting that “Count II does not list a specific ERISA statutory provision under which Plaintiffs

claims are made against Hirschvogel and [he] is accordingly afforded broad based relief under whichever ERISA provision fits Plaintiff’s allegations.” Doc. 11 at 5-6. In other words, he leaves to Hirschvogel and the Court to find every source of relief provided under ERISA, formulate his argument as to how the facts alleged in his Complaint might fit those sources of relief, and evaluate whether the claim is ultimately viable. The District Court for the Eastern District of Michigan dealt with a similar situation, in which a pro se plaintiff brought claims under the Americans with Disabilities Act without specifying a legal basis. Al-Janabi v. Wayne State Univ., No. 20-12655, 2021 WL 1224205, at *3 (E.D. Mich. Apr. 1, 2021), aff'd sub nom. Al -Janabi v. Wayne State Univ., No. 21-1399, 2021 WL 8264677 (6th Cir. Dec. 15, 2021). The court found that “[p]laintiff cannot simply cite an entire body of law ‘ADA law’ and survive a motion to dismiss.” Id. at *4. It explained that “such a complete lack of legal support cannot establish a valid claim for relief.” Id. The Court agrees with Al-Janabi that it is improper for a plaintiff to fend off a motion to

dismiss by relying on a claim’s ambiguity. However, a cursory review of ERISA’s civil enforcement provisions establishes that Count II can only possibly assert a claim under 29 U.S.C. § 1132(a)(3). Some legal context is necessary. ERISA’s civil enforcement statute, 29 U.S.C. § 1132, empowers beneficiaries to bring a civil action in four situations: (1) to obtain a fee for an administrator’s or employer’s failure to provide certain information, § 1132(a)(1)(A); (2) to recover benefits due under the plan, enforce rights under the plan, or clarify rights to future benefits under the plan, § 1132(a)(1)(B); (3) to obtain appropriate relief from a breach of fiduciary duty, § 1132(a)(2); and (4) to enjoin any act or practice which violates ERISA or obtain other appropriate equitable relief, § 1132(a)(3).

Count II cannot be construed as bringing a claim under § 1132(a)(1)(A). This provision is used by beneficiaries to obtain a fee when an administrator or employer fails to satisfy an obligation. See 29 U.S.C. § 1132(a)(1). For example, a beneficiary may receive a fee of up to $100 a day if an administrator fails to comply with a request for information which the administrator is required to produce. 29 U.S.C. § 1132(c)(1). Plaintiff acknowledges in his response brief that “[t]he failure to provide certain plan documents can merit an award of statutory fees . . . under ERISA.” Doc. 11 at 7. However, nowhere does he demand such fees in his Complaint. Count II also cannot be a claim for benefits due under § 1132(a)(2)(B) because Count I presents such a claim. The Complaint provides that “Griffin Bailey brings [Count I] under 29 U.S.C. § 1132 and seeks a determination of his right to life insurance benefits and an award of those benefits.” Doc. 1 ¶ 45. Finally, Count II is not the type of claim permitted by § 1132(a)(2). This provision permits a beneficiary to file a civil action for appropriate relief from a breach of fiduciary duty. 29 U.S.C.

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Bailey v. United of Omaha Life Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bailey-v-united-of-omaha-life-insurance-company-ohsd-2023.