Excerpt: The federal courts have continued to adapt the MetLife v. Glenn decision into their approach in an ad hoc and unpredictable fashion. To be sure, several courts have seen the case as requiring little change. Others, such as the Second Circuit in Douglas, reached conclusions that reveal a new approach to old issues. In this unpublished decision, the Second Circuit reversed and vacated a district court judgment for the disability carrier where the claimant had failed to submit her claim within the time required by the policy.

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