Gibson v. Alcoa, Inc. et al
MEMORANDUM OPINION. Signed by Honorable Harry F. Barnes on August 31, 2011. (cnn)
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF ARKANSAS
EL DORADO DIVISION
EDDIE L. GIBSON
CASE NO. 08-CV-1039
ALCOA, INC., SAPA EXTRUSIONS, INC.,
A/K/A SAPA FABRICATED PRODUCTS,
AND METLIFE GROUP, INC.
Plaintiff Eddie Gibson commenced this action pursuant to the Employee Retirement Income
Security Act of 1974 (“ERISA”), 29 U.S.C. § 1001 et seq., to recover life insurance and accidental
death and dismemberment benefits allegedly due to him under a Metropolitan Life Insurance
Company plan sponsored by his employer Alcoa, Inc. The administrative record has been filed, and
both parties have submitted briefs. (Doc. 30 and Doc. 32). The Court finds this matter ripe for
Plaintiff brings this case before the Court to seek review of Defendant Metropolitan Life
Insurance Company’s ("MetLife") denial of Plaintiff’s claims for accidental death insurance and life
insurance benefits stemming from the death of Plaintiff’s daughter. Plaintiff was employed by
Defendant Alcoa, Inc. and/or Sapa Extrusions, Inc. at all times relevant to this cause of action and
was a participant in the Alcoa Group Life Insurance Plan (the “Plan”). These plan benefits were
administered by MetLife. Under the Plan, Plaintiff was entitled to elect accidental death and
dismemberment insurance coverage for qualified dependents as well as life insurance coverage for
qualified dependents. G-12 and G-18.
Latay Gibson Stevenson, daughter of the Plaintiff, was born September 11, 1982, and under
the terms of the Plan, Latay, for some period of time, qualified as a dependent child of the Plaintiff.
Latay passed away as the result of an automobile accident on September 8, 2003. G-72. At the time
of her death, she was 20 years old and married to Demeno Artez Stevenson. G-72 and G-52. At
what point Latay might have ceased to qualify as a dependent of the Plaintiff is the central disputed
issue in this case.
After Latay’s death, Plaintiff filed a dependent life insurance claim for $10,000. This claim
was denied by MetLife based upon their determination that Latay no longer qualified as a dependent
of Plaintiff because she was married at the time of her death. G-56. After appealing this denial,
MetLife reviewed the claim and denied it for the second time. G-39. While it is not reflected in the
Administrative Record filed with the Court, both parties have admitted in their pleadings that
Plaintiff also made a claim in 2007 for accidental death benefits under the Plan in the amount of
$200,000. This claim was also denied by MetLife based upon their determination that Latay was
not a qualified dependent under the Plan. Doc. 17, ¶ 21 and Doc. 18, ¶ 21.1
Under the terms of the Plan, dependents eligible for coverage under life insurance and
accidental death and dismemberment coverage include a covered employee’s:
“...legal spouse or common-law spouse (as determined by state law);
There are no documents in the administrative record that clearly and explicitly indicate what
benefits Plaintiff was entitled to under the Plan. However, both parties agree that dependent life
insurance and dependent accidental death and dismemberment insurance are the only potential benefits
implicated in this case. For purposes of analyzing the legal merits of Plaintiff’s claim, the Court will
assume that Plaintiff did in fact hold life insurance and accidental death and dismemberment insurance on
his daughter, Latay Gibson Stevenson, in the amounts of $10,000 and $200,000 respectively.
...unmarried children under age 19 who are principally supported by
...unmarried child of any age who is not capable of self-support due to a
physical or mental disability that occurred before age 19 (or age 25 if a
full-time student) and who is principally supported by [employee]. Proof of
disability may be required; and
...unmarried child age 19 to age 25 if he or she is enrolled as a full-time
student in an accredited school or recognized course of study or training and
principally supported by [employee]. Proof of student status and support
may be required. [remaining language omitted].” (emphasis added). G-3.
Upon Latay Gibson Stevenson’s marriage in 2001, the point at which she was clearly no
longer a qualified dependent under the Plan, Plaintiff contends that MetLife was notified of her
change in status yet continued to withhold insurance premiums for dependent life insurance and
dependent accidental death and dismemberment insurance from Plaintiff’s earnings even after
Latay’s death in 2003. MetLife does not appear to dispute that Plaintiff informed them of Latay’s
change in status. MetLife also does not dispute that it continued to withhold life insurance
premiums after Latay’s change in status. However, MetLife has submitted an affidavit from Brenda
Barlek, Alcoa’s Manager of Heather and Welfare and Customer Service, stating that Plaintiff paid
only one accidental death and dismemberment insurance premium that covered all of Plaintiff’s
dependents. MetLife contends that, because Plaintiff’s wife has always been covered as a dependent
under the accidental death and dismemberment policy, no “extra” accidental death insurance
premiums were ever deducted for Latay Gibson Stevenson.
STANDARD OF REVIEW
The Court has already determined that the proper standard of review in this case is a de novo
review (Doc. 41) conducted pursuant to Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 115,
109 S.Ct. 948, 956-57, 103 L.Ed.2d 80 (1989).
Plaintiff contends that, because MetLife continued to deduct life insurance and accidental
death and dismemberment insurance premiums even after being notified that Latay was no longer
a dependent, MetLife should be estopped from now denying that Latay was a qualified dependent
under the plan and full benefits should be paid to Plaintiff. Assuming arguendo that these premiums
were deducted after Plaintiff notified MetLife that Latay no longer qualified as a dependent under
the Plan, Plaintiff cannot prevail under a theory of equitable estoppel.
The Eighth Circuit will only recognize a claim for equitable estoppel “where an employer
(or plan administrator) has expressed a ‘specific’ intent to be bound by either an oral or written
modification of the plan.” Slice v. Sons of Norway, 34 F.3d 630, 634 (8th Cir. 1994). Furthermore,
“[e]stoppel can only be employed when the terms of the plan are ambiguous and the
communications constituted an interpretation of that ambiguity .... When the alleged
misrepresentations flatly contradict the unambiguous language of the plan, an estoppel claim is not
available.” Id. (internal quotation marks omitted). See also, Algren v. Pirelli Armstrong Tire Corp.,
197 F.3d 915 (8th Cir.1999). In sum, equitable estoppel may not be used to vary or contradict the
language of an ERISA plan or to enlarge the benefits available under the plan where plan language
In this case, the language in the Plan regarding whether an individual qualifies as a
dependent is clear and unambiguous as applied to the factual situation before the Court. The Plan
provides, in sum, that (1) a child is no longer a dependent once they reach age 19, unless they are
disabled or qualify as a full time student, and (2) a child who is married, no matter their age,
disability, or student status, is not a qualified dependent.
Latay Gibson Stevenson’s Certificate of Death clearly indicates that she was married to
Demeno Artez Stevenson at the time of her death. G-72. Furthermore, when Plaintiff filled out the
MetLife life insurance claim form in January 2004, he listed on this form that Latay was married at
the time of her death. G-52. Plaintiff claims that Latay was in fact separated from her husband and
living with Plaintiff during the period leading up to her death. Assuming these facts to be true,
Latay’s separation from her husband or financial dependence on the Plaintiff would have no affect
her on status as a dependent under the unambiguous Plan language. Latay was still legally married
at her death. This fact alone precludes her from qualifying as a dependent.
While MetLife appears to have continued to treat Latay as a dependent for purposes of
deducting life insurance premiums, the Plan clearly provides that a married child cannot qualify as
a dependent. The Court finds the Plan language to be unambiguous, therefore, Plaintiff may not
utilize the doctrine of equitable estoppel to collect life insurance or accidental death and
dismemberment insurance benefits for the death of Latay Gibson Stevenson. However, Plaintiff is
entitled to reimbursement for any life insurance premiums withheld by MetLife after MetLife
received notification of Latay Gibson Stevenson’s change in dependent status. In light of the
evidence submitted by MetLife showing no separate premium for accidental death and
dismemberment insurance being withheld for Latay Gibson Stevenson and Plaintiff’s failure to point
to any evidence in the record to the contrary, the Court finds no basis for reimbursement of
accidental death and dismemberment insurance premiums.
For the reasons stated above, the Court finds that MetLife’s denial of life insurance benefits
and accidental death and dismemberment insurance benefits to Plaintiff should be upheld. The
Court also finds that Plaintiff is entitled to reimbursement from MetLife for all life insurance
premiums charged to Plaintiff after MetLife was notified of Latay Gibson Stevenson’s change in
dependent status. A judgment of even date, consistent with this opinion, shall issue.
IT IS SO ORDERED, on this 31st day of August, 2011.
/s/ Harry F. Barnes
Hon. Harry F. Barnes
United States District Judge
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