United States District Court, D. Alaska
ORDER REGARDING DEFENDANT'S MOTION TO DISMISS AT
DOCKET 28
RALPH
R. BEISTLINE U.S. DISTRICT COURT JUDGE
Before
the Court at Docket 28, Defendant Metropolitan Life Insurance
Company moves for dismissal of Plaintiff Karen Seekatz's
First, Second, and Fourth Causes of Action. Plaintiff opposes
at Docket 30 and Defendant replies at Docket 38.
BACKGROUND
Plaintiff
alleges that in the fall of 2011, as an employee of British
Petroleum, she enrolled for dependent life insurance in the
amount of $250, 000 for her husband, Matt
Seekatz.[1] This was the maximum allowable through
BP's Group Universal Life Plan (the Plan), and Plaintiff
began making premium payments on November 15, 2011, which
continued bi-weekly until Mr. Seekatz passed away on May 6,
2012.[2] Plaintiff submitted a claim for the $250,
000 death benefit in September 2012.[3] Although Plaintiff maintains
that all necessary paperwork was completed under the Plan,
Defendant denied her claim based on purported failure to
submit a statement of health and instead paid out the basic
death benefit of $20, 000 per the Plan.[4]
Plaintiff
has asserted four causes of action against Defendant: breach
of fiduciary duties, equitable relief under 29 U.S.C. §
1132(a)(3), breach of contract, and tortious breach of
contract.
STANDARD
OF REVIEW
A
motion to dismiss under Federal Rule of Civil Procedure
12(b)(6) may be granted “only if it is clear that no
relief could be granted under any set of facts that could be
proven consistent with the allegations.”[5] In deciding the
motion, not only must a court accept all material allegations
in the complaint as true, but the complaint must be
construed, and all doubts resolved, in the light most
favorable to the plaintiff.[6]
“While
legal conclusions can provide the framework of a complaint,
they must be supported by factual
allegations.”[7] Additionally, although a complaint
"need not contain detailed factual allegations, it must
plead enough facts to state a claim of relief that is
plausible on its face."[8]A court should not look to
“whether a plaintiff will ultimately prevail but
whether the claimant is entitled to offer evidence to support
the claims.”[9]
DISCUSSION
The
Employee Retirement Income Security Act of 1974 (ERISA)
establishes minimum standards and extensive rules to protect
the interests of employee benefit plan participants and their
beneficiaries.[10] ERISA includes civil enforcement
provisions under 29 U.S.C. § 1132, which are "the
exclusive vehicle for actions by ERISA-plan participants and
beneficiaries asserting improper processing of a claim for
benefits."[11] Under Section 1132(a)(1), a civil action
can be brought by a plan participant or beneficiary "to
recover benefits due to him under the terms of his plan, to
enforce his rights under the terms of the plan, or to clarify
his rights to future benefits under the terms of the
plan." Section 1132(a)(2) allows for a civil suit for
appropriate relief on behalf of the plan for breach of
fiduciary duty.[12] Of final relevance to the present case,
Section 1132(a)(3) allows for a civil suit to enjoin any
actions or practices in violation of ERISA or the terms of
the plan or "to obtain other appropriate equitable
relief to redress such violations or to enforce any
provisions of [ERISA] or the terms of the plan."
A.
Preemption
The
parties do not dispute that ERISA supersedes "any and
all State laws insofar as they may now or hereafter relate to
any employee benefit plan."[13] Defendant therefore
argues that Plaintiff's first and fourth causes of
action, breach of fiduciary duty and tortious breach of
contract respectively, fall under State law claims
specifically preempted by ERISA and should be dismissed.
Plaintiff effectively concedes as much in her opposition,
acknowledging that all remedies must lie within ERISA and
making no defense of the first cause of action.[14] The Court
concurs that Plaintiff's Tortious Breach of Contract
cause of action is clearly a State law claim, but recognizes
that a breach of fiduciary duty cause of action could be
raised under Section 1132(a)(2) for injuries to the Plan as a
whole. However, Plaintiff has failed to assert this basis for
her first cause of action in her opposition to the motion to
dismiss. Even if Plaintiff had not abandoned this cause of
action, the Court finds no support in Plaintiff's Amended
Complaint for a breach of fiduciary duty claim under ERISA
beyond her Section 1132(a)(3) claim addressed below.
Accordingly, the Court dismisses Plaintiff's first and
fourth causes of action for Breach of Fiduciary Duties and
Tortious Breach of Contract.
B.
Section 1132 Claims
Plaintiff's
remaining causes of action, breach of contract and equitable
relief, align with Sections 1132(a)(1) and 1132(a)(3)
respectively. As discussed above, a state law breach of
contract claim would be preempted. However, Defendant does
not oppose the conversion of Plaintiff's breach of
contract claim into a denial of benefits claim under Section
1132(a)(1) claim and the Court agrees. Under such a
conversion, Plaintiff's second cause of action is
therefore undisputed in the present motion to dismiss as a
claim for wrongful denial of benefits.
1.
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