Papenfus v. Flagstar Bankcorp, Inc.

517 F. Supp. 2d 969, 42 Employee Benefits Cas. (BNA) 2579, 2007 U.S. Dist. LEXIS 78798, 2007 WL 3071406
CourtDistrict Court, E.D. Michigan
DecidedOctober 18, 2007
DocketCivil 07-10925
StatusPublished
Cited by2 cases

This text of 517 F. Supp. 2d 969 (Papenfus v. Flagstar Bankcorp, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Papenfus v. Flagstar Bankcorp, Inc., 517 F. Supp. 2d 969, 42 Employee Benefits Cas. (BNA) 2579, 2007 U.S. Dist. LEXIS 78798, 2007 WL 3071406 (E.D. Mich. 2007).

Opinion

OPINION AND ORDER

JOHN FEIKENS, District Judge.

Plaintiff Kurt Papenfus (“Papenfus”) brought this suit against Defendants Flagstar Bankcorp, Inc. (“Flagstar”) and Hartford Life (“Hartford”) alleging that they wrongfully denied him $50,000 in proceeds from a life insurance policy on his deceased wife. Papenfus has moved for summary judgment arguing (1) that Defendants are estopped from denying him benefits and (2) that Defendants* decision to deny him benefits was arbitrary and capricious. For the reasons set forth below, I find that Defendants are estopped from denying Papenfus’s claim. I, therefore, grant Papenfus’s motion for summary judgment.

I. FACTUAL AND PROCEDURAL BACKGROUND

Papenfus was employed by Flagstar and participated in an employee welfare benefit plan (the “Plan”) that included spousal life insurance. The Plan was administered by Hartford. Papenfus elected $100,000 in life insurance for his wife. The enrollment form stated that “[ajmounts elected over $50,000 will require proof of good health.” 1

Another part of the Plan defined Evidence of Good Health: “Evidence of Good Health is information about a person’s health from which We can determine if coverage or increases in coverage will be effective. Information may include questionnaires, physical exams, or written documentation as required by Us.” 2 The Plan also contained information regarding notification. “We, your employer and/or Benefit Administrator will notify You of approvals. We will notify You, in writing, of any disapprovals.” 3

Defendants never asked Papenfus for evidence of his wife’s good health and Papenfus never submitted any. After Papenfus completed the enrollment forms, the premium applicable for $100,000 in spousal life insurance was regularly deducted from his paycheck. In addition, each January, Papenfus received a “Benefit Statement” that indicated that he was covered by $100,000 of spousal life insurance. 4

*972 When Papenfus’s spouse passed away, he made a claim for $100,000 in benefits. His claim for the full $100,000 was denied because he had not provided evidence of his wife’s good health. As a result, he was paid $50,000. Hartford upheld the denial on appeal and Papenfus filed this action in Wayne County Circuit Court, bringing claims for breach of contract and promissory estoppel against both Hartford and Flagstar and an additional claim of negligence against Flagstar. Defendants removed this action to federal court because Papenfus’s claims relate to the Employee Retirement Income Security Act (“ERISA”). Papenfus filed an amended complaint, recasting his claims as causes of action under ERISA and brought this motion for summary judgment claiming (1) that Defendants are estopped from denying his claim and (2) that their decision to deny his claim was arbitrary and capricious.

II. ANALYSIS

A. Summary Judgment

Summary judgment is proper “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56 (c). A fact is material if it might affect the outcome of the suit under the governing law. See Anderson v. Liberty Lobby Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). To show the existence of a genuine issue, the nonmoving party must have more than a scintilla of evidence to support its position; there must be sufficient evidence that a jury could reasonably find for the nonmoving party. See Id. at 252, 106 S.Ct. 2505. In determining whether there is a genuine issue of material fact, the court must view the evidence and draw all reasonable inferences in the light most favorable to the non-moving party. See Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986).

B. Estoppel

1. Applicability of Estoppel

The Sixth Circuit “has recognized that promissory estoppel is a viable theory in ERISA welfare benefit actions.” Moore v. LaFayette Life Insurance Company, 458 F.3d 416, 428 (6th Cir.2006). “Principles of estoppel, however, cannot be applied to vary the terms of unambiguous plan documents; estoppel can only be invoked in the context of ambiguous plan provisions.” Sprague v. Gen. Motors Corp., 133 F.3d 388, 404 (6th Cir.1998). Estoppel claims “are not claims for denial of benefits and are, therefore, addressed in the first instance in the district court, requiring no deference to any administrator’s action or decision.” Moore, 458 F.3d at 427.

Because this action involves an ERISA welfare benefits plan, whether estoppel can be invoked hinges upon whether the claim is based on an ambiguous plan provision. A plan provision is ambiguous if it is subject to two or more reasonable interpretations. See Wulf v. Quantum Chemical Corp., 26 F.3d 1368, 1376 (6th Cir.1994). Defendants argue that under the language of the Plan Papenfus was required to submit evidence of good health *973 for his wife in order to qualify for $100,000 in spousal life insurance. While this is certainly a plausible reading of Plan documents, it is not the only reasonable interpretation.

After reading the Plan, a reasonable person could believe that the Plan administrator is responsible for initiating the submission of evidence of good health and for informing an enrollee if his application is incomplete. The Plan defines evidence of good health as follows: “Evidence of Good Health is information about a person’s health from which We can determine if coverage or increases in coverage will be effective. Information may include questionnaires, physical exams, or written documentation as required by Us.” The phrase “as required by US” seems to indicate that the Plan administrator will inform the enrollee of what is required. This interpretation is further buttressed by the list of examples of evidence of good health found in the definition. It seems very unlikely that a potential enrollee is required under this Plan language to fill out a questionnaire, submit to an examination, or produce written documents without a specific request from the Plan administrator detailing what is required.

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517 F. Supp. 2d 969, 42 Employee Benefits Cas. (BNA) 2579, 2007 U.S. Dist. LEXIS 78798, 2007 WL 3071406, Counsel Stack Legal Research, https://law.counselstack.com/opinion/papenfus-v-flagstar-bankcorp-inc-mied-2007.