Tiffoni Hurt, et al. v. Metropolitan Life Insurance Company

CourtDistrict Court, N.D. Ohio
DecidedMay 1, 2026
Docket1:25-cv-02722
StatusUnknown

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

Bluebook
Tiffoni Hurt, et al. v. Metropolitan Life Insurance Company, (N.D. Ohio 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

Tiffoni Hurt, et al., ) CASE NO. 1:25 CV 2722 ) ) Plaintiffs, ) JUDGE PATRICIA A. GAUGHAN ) vs. ) ) Metropolitan Life Insurance Company, ) ) Memorandum Opinion and Order ) Defendant. )

INTRODUCTION This matter is before the Court upon defendant Metropolitan Life Insurance Company’s Motion to Dismiss Plaintiffs’ Complaint. (Doc. 8.) This is a federal insurance contract benefits case. For the reasons that follow, Metropolitan Life Insurance Company’s Motion to Dismiss Plaintiff’s Complaint is GRANTED. FACTS For purposes of ruling on the pending motion to dismiss, all well-plead factual allegations in plaintiff’s Complaint (Doc. 1) are presumed true. Denise Owens (the “Insured”) began working for the United States Postal Service (the “USPS”) in 1984. In February 2025, the Insured was hospitalized after a cancer diagnosis. Although the Insured “stopped actively working” during her hospitalization and was “in the process of retiring from the USPS,” she remained employed by the USPS at the time of her death on April 10, 2025. As an employee of the USPS, the Insured was covered under the Federal Employees’ Group Life Insurance (“FEGLI”) policy. Defendant Metropolitan Life Insurance Company (“MetLife”) administers the claims process of the FEGLI program for the federal government. On March 28, 2025, the Insured executed a beneficiary designation form (the “Designation”), which named plaintiffs Tiffoni Hurt, Samuel Foster, Terri-Hurt Collins, and Shyla

Armstrong (together, “Plaintiffs”) each a 25% beneficiary of her FEGLI death benefit. The Designation was signed by two people who witnessed the Insured sign the Designation. The Insured then mailed the Designation to the Office of Personnel Management (“OPM”). OPM received the Designation on April 9, 2025. The Insured died on April 10, 2025. After the Insured’s death, Plaintiffs submitted claims for the FEGLI death benefit. MetLife denied Plaintiffs’ claims because the Designation “was not received by the employing agency prior to the death of [the Insured]” and, thus, the death benefit was instead payable to the Insured’s widower. In turn, Plaintiffs filed this action seeking a declaratory judgment that they are entitled to the Insured’s FEGLI death benefit. MetLife has now moved to dismiss the complaint. Plaintiffs

oppose the motion. STANDARD OF REVIEW When considering a motion to dismiss pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure, the factual allegations of the complaint must be taken as true and construed in the light most favorable to the plaintiff. Comtide Holdings, LLC v. Booth Creek Mgmt. Corp., 335 F. App’x 587, 588 (6th Cir. 2009) (citing Bassett v. Nat’l Collegiate Athletic Ass’n, 528 F.3d 426, 430

2 (6th Cir. 2008)). That said, the complaint must set forth “more than the bare assertion of legal conclusions.” In Re DeLorean Motor Co., 991 F.2d 1236, 1240 (6th Cir. 1993) (citing Scheid v. Fanny Farmer Candy Shops, Inc., 859 F.2d 434, 436 (6th Cir. 1988)). The Court is not required to accept as true legal conclusions or unwarranted factual inferences. In re Sofamor Danek Group, Inc., 123 F.3d 394, 400 (6th Cir. 1997) (citing Morgan v. Church’s Fried Chicken, 829 F.2d 10, 12 (6th Cir. 1987)). A cause of action fails to state a claim upon which relief may be granted when it lacks

“plausibility in [the] complaint.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 564 (2007). A pleading must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 677–78 (2009). The factual allegations in the pleading must be sufficient to raise the right to relief above the speculative level on the assumption that all the allegations in the complaint are true. Twombly, 550 U.S. at 555. The plaintiff is not required to include detailed factual allegations, but must provide more than “an unadorned, the-defendant- unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 555). A complaint that merely offers legal conclusions or a simple recitation of the elements of a cause of action will not meet this pleading standard. Id.

ANALYSIS FEGLI is established and governed by the Federal Employees’ Group Life Insurance Act, 5 U.S.C. § 8701 et seq. (“FEGLIA”). Congress enacted the FEGLIA in 1954, “to provide low-cost group life insurance to Federal employees.” Hillman v. Maretta, 569 U.S. 483, 486 (2013) (quotation marks omitted).

3 Relevant here, FEGLIA mandates the “order of precedence” for distributing any death benefits in force on an employee at the date of the employee’s death: “[f]irst to the beneficiary or beneficiaries designated by the employee . . . . Second, if there is no designated beneficiary, to the widow or widower of the employee. . . .” 5 U.S.C. § 8705(a) (detailing the order of precedence from first to sixth). Importantly, the statute mandates that any beneficiary designation must be “a signed and witnessed writing received before death in the employing office or, if insured because of receipt of annuity or of benefits under subchapter I of chapter 81 of this title as provided by section

8706(b) of this title, in the Office of Personnel Management. . . . “[A] designation, change, or cancellation of beneficiary in a will or other document not so executed and filed has no force or effect. Id. See Graber v. Metropolitan Life Ins. Co., 855 F. Supp. 2d 673, 675 (N.D. Ohio 2012) (“Notably, the FEGLIA statute requires that a properly executed beneficiary designation form must be ‘received before death in the employing office’ to be effective.” (quoting 5 U.S.C. § 8705(a))). Here, for the Designation to be valid under the plain language of the FEGLIA statute, it had to be signed, witnessed, and received by her employing office before her death. As an employee of the USPS at the time of her death, the USPS was her “employing office.” In their Complaint, Plaintiffs allege that the Designation was signed and witnessed, but they concede the Designation

was not received by the USPS before the Insured’s death. Rather, the Insured sent the Designation to OPM. For this reason, Plaintiffs’ claims fail. They have no valid claim for the Insured’s death benefits and their Complaint must be dismissed. Plaintiffs’ arguments to the contrary are unavailing. They acknowledged that courts should strictly construe whether an employee met the requirements of the FEGLIA statute but then ask this Court to deem the Insured’s subjective intentions and reliance on her agency’s misguidance

4 superior to the plain text of the law.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Larry Bonner v. Metropolitan Life Insurance Co
621 F.3d 530 (Sixth Circuit, 2010)
Carolyn Morgan v. Church's Fried Chicken
829 F.2d 10 (Sixth Circuit, 1987)
Vivian J. Scheid v. Fanny Farmer Candy Shops, Inc.
859 F.2d 434 (Sixth Circuit, 1988)
Hillman v. Maretta
133 S. Ct. 1943 (Supreme Court, 2013)
Bassett v. National Collegiate Athletic Ass'n
528 F.3d 426 (Sixth Circuit, 2008)
Comtide Holdings, LLC v. Booth Creek Management Corp.
335 F. App'x 587 (Sixth Circuit, 2009)
Graber v. Metropolitan Life Insurance
855 F. Supp. 2d 673 (N.D. Ohio, 2012)

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