09-2326 Edwards v. Briggs & Stratton Retirement Plan

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Insurance
ERISA

Where an ERISA claimant failed to file a timely administrative appeal, the plan is not required to consider the appeal.

“In this case, the Plan has fixed a clear deadline of 180 days for filing administrative appeals from denials of benefits, and the Plan has the right to enforce that deadline. Also, though counsel for the Plan conceded at oral argument in this appeal that it is within the Plan administrator’s discretion to entertain an untimely appeal, Edwards has never offered an explanation for the untimeliness of her appeal that would warrant such an exercise of discretion in her favor. Finally, it seems consistent neither with the policies underlying the requirement of exhaustion of administrative remedies in ERISA cases nor with judicial economy to import into the exhaustion requirement the substantial compliance doctrine. To so hold would render it effectively impossible for plan administrators to fix and enforce administrative deadlines while involving courts incessantly in detailed, case-by-case determinations as to whether a given claimant’s failure to bring a timely appeal from a denial of benefits should be excused or not. Accordingly, we conclude that Edwards’s failure to file a timely administrative appeal from the Plan’s initial denial of benefits is not excused on grounds of substantial compliance.”

Affirmed.

09-2326 Edwards v. Briggs & Stratton Retirement Plan

Appeal from the United States District Court for the Eastern District of Wisconsin, Goodstein, Mag. J., Murphy, J.

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