ERISA Life Policy Requires Active Employment to Order Increase in Benefits
Post 5259
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In Katherine Crow Albert Guidry, Individually And On Behalf Of The Estate Of Jason Paul Guidry v. Metropolitan Life Insurance Company, et al, Civil Action No. 25-18-SDD-RLB, United States District Court, M.D. Louisiana (January 7, 2026) Guidry brought suit to recover life insurance proceeds she alleges were wrongfully withheld following her husband’s death on January 9, 2024.
FACTUAL BACKGROUND
Jason Guidry was employed by Waste Management, which provided life insurance coverage through Metropolitan Life Insurance Company (“MetLife”). Plaintiff contends that after Jason’s death, the defendants (MetLife, Waste Management, and Life Insurance Company of North America (“LINA”)) engaged in conduct intended to confuse and ultimately deny her entitlement to $504,000 in Optional Life Insurance proceeds.
The Complaint cites violations of the Employee Retirement Income Security Act (ERISA) and three Louisiana statutes.
Plaintiff transmitted Jason Guidry’s death certificate to MetLife, which reflected January 9, 2024, as the date of death. On February 27, 2024, MetLife paid Plaintiff $63,018.12 for Basic Life Insurance benefits plus interest. However, MetLife denied the claim for Optional Life Insurance, explaining Jason Guidry elected Optional Life Insurance coverage to be effective January 1, 2024. The Death Certificate issued by the State of Louisiana indicates that Jason Guidry passed away on January 9, 2024. MetLife concluded Jason Guidry was not “actively at work” on January 1, 2024, as required under the Plan for the optional coverage to take effect.
LAW:
The central legal issues:
1. whether the relevant employee benefit plan vests discretionary authority in the plan administrator to determine eligibility for benefits and interpret plan terms, and
2. whether ERISA preempts all related state law claims.
ANALYSIS
Where the plan administrator has discretionary authority to determine eligibility for benefits or to construe the terms of the plan, courts must base their review of the legal and factual findings of the administrator’s decision under an abuse of discretion standard.
The Court found that the Plan clearly vests the Administrator with discretionary authority to determine eligibility for benefits and to construe the terms of the plan.
The Motion was Granted.
The Court found that Plaintiff has no claim against Waste Management. Waste Management did not make the decision to deny Optional Life Insurance benefits. Accordingly, the Court granted Waste Management’s Motion for Judgment on the Administrative Record.
Liability of MetLife
Plaintiff’s claim against MetLife also lacks merit. Under the abuse of discretion standard, a court’s review of the administrator’s decision need not be particularly complex or technical; it need only assure that the administrator’s decision falls somewhere on a continuum of reasonableness – even if on the low end.
The Court found that MetLife’s denial of Plaintiff’s claim for Optional Life Insurance coverage was not an abuse of discretion. MetLife reasonably denied coverage on the basis that Jason Guidry was not “actively at work” on the date the Optional Life Insurance coverage took effect. Accordingly, MetLife’s Motion for Judgment on the Administrative Record was granted.
CONCLUSIONS
1. Life Insurance Company of North America’s Motion for Partial Summary Judgment on the Issue of ERISA Preemption was GRANTED;
2. Metropolitan Life Insurance Company’s and Waste Management National Services, Inc.’s Motion for Partial Summary Judgment was GRANTED;
3. Waste Management’s Motion for Judgment on the Administrative Record was GRANTED;
4. MetLife’s Motion for Judgment on the Administrative Record was GRANTED;
5. LINA’s Response Brief on the Merits, which the Court construes as a Motion for Judgment on the Administrative Record, was GRANTED;
6. Plaintiff’s Opening Brief on the Merits,which the Court construes as a Motion for Judgment on the Administrative Record, was DENIED.
7. The Motions to Dismiss filed by MetLife and Waste Management was terminated as moot and
8. Plaintiff’s action was dismissed with prejudice.
ZALMA OPINION
ERISA claims are federal and always resolved in the USDC. The optional coverage Mr. Guidrey ordered needed to be ordered while he was actively employed. Since he was in hospital close to death he attempted to increase his life insurance benefits. He died before he could go back to work and get the benefits he desired and the ERISA decision maker properly applied the policy.
(c) 2025 Barry Zalma & ClaimSchool, Inc.
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Failure to Respond to Motion to Dismiss is Agreement to the Motion
Post 5259
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In Mercury Casualty Company v. Haiyan Xu, et al., No. 2:23-CV-2082 JCM (EJY), United States District Court, D. Nevada (January 6, 2026) Plaintiff Mercury Casualty Company (“plaintiff”) moved to dismiss. Defendant Haiyan Xu and Victoria Harbor Investments, LLC (collectively, “defendants”) did not respond.
This case revolves around an insurance coverage dispute when the parties could not be privately resolved, litigation was initiated in the Eighth Judicial District Court of Nevada. Plaintiff subsequently filed for a declaratory judgment in this court.
On or about April 15, 2025, the state court action was dismissed with prejudice pursuant to a stipulation following mediation. Plaintiff states that the state court dismissal renders its ...
Overwhelming Evidence of Insurance Fraud Sustains Conviction - One Fraud Fails in Minnesota
Post 5258
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In State of Minnesota v. Mark John Jenni, No. A25-0111, Court of Appeals of Minnesota (January 5, 2026) dealt with an insurance coverage issue because Mr. Jenni, in July 2023, obtained an insurance policy with Liberty Mutual Insurance for a home in Park Rapids, Hubbard County, Minnesota based on false representations, only to find himself charged with insurance fraud.
FACTS
On his application, Jenni stated that the property was his primary residence, that he had purchased it in 2023, that it was not under construction or renovation, and that there had been no recent insurance claims or cancellations on the property. About a month after securing coverage, Jenni filed a claim for a reported burglary involving over $80,000 in stolen tools and property damage. He did not report the ...
Insured Must Give Prompt Notice of Loss
Post 5256
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Once The Insured Knows There is Damage It is Obligated to Report the Loss to the Insurer
In Greater St. Stephen Ministries, Inc. v. Mt. Hawley Insurance Company, No. 24-cv-3130 (AS), United States District Court, S.D. New York (January 2, 2026) resolved a case brought by a church against an insurance company for denying coverage after Hurricane Ida. After discovery, the insurance company moved for summary judgment because it claimed the insured breached a material condition of the policy.
BACKGROUND
Greater St. Stephen Ministries, Inc., a church located in Louisiana, owned property that suffered damage from Hurricane Ida on August 29, 2021. The property was insured under a policy with Mt. Hawley Insurance Company, which required the insured to provide “prompt notice” of any loss or damage, ...
Court Must Follow Judicial Precedent
Post 5252
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Insurance Policy Interpretation Requires Application of the Judicial Construction Doctrine
In Montrose Chemical Corporation Of California v. The Superior Court Of Los Angeles County, Canadian Universal Insurance Company, Inc., et al., B335073, Court of Appeal, 337 Cal.Rptr.3d 222 (9/30/2025) the Court of Appeal refused to allow extrinsic evidence to interpret the word “sudden” in qualified pollution exclusions (QPEs) as including gradual but unexpected pollution. The court held that, under controlling California appellate precedent, the term “sudden” in these standard-form exclusions unambiguously includes a temporal element (abruptness) and cannot reasonably be construed to mean ...
Lack of Jurisdiction Defeats Suit for Defamation
Post 5250
Posted on December 29, 2025 by Barry Zalma
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He Who Represents Himself in a Lawsuit has a Fool for a Client
In Pankaj Merchia v. United Healthcare Services, Inc., Civil Action No. 24-2700 (RC), United States District Court, District of Columbia (December 22, 2025)
FACTUAL BACKGROUND
Parties & Claims:
The plaintiff, Pankaj Merchia, is a physician, scientist, engineer, and entrepreneur, proceeding pro se. Merchia sued United Healthcare Services, Inc., a Minnesota-based medical insurance company, for defamation and related claims. The core allegation is that United Healthcare falsely accused Merchia of healthcare fraud, which led to his indictment and arrest in Massachusetts, causing reputational and business harm in the District of Columbia and nationwide.
Underlying Events:
The alleged defamation occurred when United ...
Zalma’s Insurance Fraud Letter
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ZIFL Volume 29, Issue 24
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Zalma’s Insurance Fraud Letter (ZIFL) continues its 29th year of publication dedicated to those involved in reducing the effect of insurance fraud. ZIFL is published 24 times a year by ClaimSchool and is written by Barry Zalma. It is provided FREE to anyone who visits the site at http://zalma.com/zalmas-insurance-fraud-letter-2/
Zalma’s Insurance Fraud Letter
Merry Christmas & Happy Hannukah
Read the following Articles from the December 15, 2025 issue:
Read the full 19 page issue of ZIFL at ...
