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Text of First Circuit Opinion: Failure to Include Time Limit for Filing of Civil Suit in Claim Denial Letter Renders Limitations Period Inapplicable (PDF)
U.S. Court of Appeals for the First Circuit
Mar. 15, 2016
"Claimants are obviously more likely to read information stated in the final denial letter, as opposed to included (or possibly buried) somewhere in the plan documents, particularly since, as was the case here, plan documents could have been given to a claimant years before his claim for benefits is denied. The [DOL], recognizing this, has required that the denial letters themselves include certain information that the Department has deemed critical to ensuring a fair opportunity for review. We think it clear that the Department has included the plan-imposed time limit for filing suit among this required information.... [We] conclude that MetLife's failure to include the time limit in the final denial letter rendered, as a matter of law, the contractual three-year limitations period altogether inapplicable." [Santana-Diaz v. Metropolitan Life Ins. Co., No. 15-1273 (1st Cir. Mar. 14, 2016)]
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