Court Refuses to Dismiss Claims Administrator as Defendant in ERISA Disability Case
Carla Pippin stopped working due to a medical condition in January 2002. She began receiving ERISA disability benefits from her employer’s plan. The third-party claims administrator, Broadspire Services, terminated Pippin’s benefits approximately two years later under the plan’s “any occ” definition of disability.
After Broadspire denied Pippin’s internal appeal, she filed suit seeking past-due and future benefits from the plan. Broadspire moved to dismiss, arguing that it was not a proper defendant under ERISA because it did not shoulder any financial responsibility for paying claims under the plan. Broadspire contended that the employer and the plan itself were the proper defendants. Pippin asserted that Broadspire was a proper party because it had authority to accept and deny claims under the plan.
The court denied Broadspire’s motion to dismiss, holding in part as follows:
The proceedings in this case are at a very early stage. Having accepted all well pleaded facts, made all reasonable inferences in plaintiff's favor, and made a liberal reading of the complaint, we do not find that dismissal of the lawsuit would be proper. Indeed, we must accept Pippin's assertion that Broadspire had the authority to determine the final review of her claim for disability benefits. As Pippin contends that Broadspire maintains discretionary authority over the plan, Broadspire is a fiduciary to the plan, and therefore was properly named as a defendant. Accordingly, the defendant's motion to dismiss the plaintiff's complaint against the plan administrator should be denied because the defendant as movant for dismissal under Rule 12(b)(6) has not met its burden to prove that the plaintiff ‘can prove no set of facts in support of his claim which would entitle him to relief.’
The cite is Pippin v. Broadspire Services, Inc., 2006 WL 2588009 (