Haysman purchased life insurance as part of an ERISA plan established by his employer, Patcomp Inc. After Haysman’s death and the denial of his beneficiaries’ claim for death benefits, plaintiffs brought suit under ERISA against MetLife, which issued the coverage, and an entity called Bill Lucas & Associates, Inc. (BLA), described by plaintiffs as being “actively engaged in soliciting, enrolling, and servicing the Employee Benefit Plan of Patcomp and its employees.”
The complaint alleged that BLA was “the agent and representative of Defendant Patcomp in the administration and carrying out of the employee benefit plan and acted on behalf of the Plan Administrator in carrying out the requirements of the plan.” Finally, the complaint asserted that BLA “advis[ed] employees of Patcomp on all aspects of said benefit plans, including determinations of eligibility for benefits.”
BLA moved to dismiss the complaint, asserting that it was “utterly devoid of any contention that [BLA] is a plan administrator or fiduciary subject to liability as an ERISA entity.” Plaintiffs argued that they had “properly alleged that Defendant BLA was a ‘de facto Plan Administrator with control over the employee benefits program of Patcomp.’”
The court denied the motion to dismiss, concluding that plaintiffs had “sufficiently alleged that Defendant BLA is a plan administrator.” Among the allegations, the court noted, was the “contention that Defendant BLA was somehow involved in determining whether individuals were eligible for plan benefits.” According to the court, “[t]his type of activity would render Defendant BLA a plan administrator and subject to suit under ERISA for the improper denial of benefits.”
The court acknowledged that “it very well may be that Defendant BLA does not qualify as a plan administrator.” At this early stage of the litigation, however, only a “short and plain statement” of the claim showing entitlement to relief was required.
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