Fourth Circuit Rejects Equitable Estoppel Claims for Life Insurance Coverage

Leslie Moon, the widow of a deceased employee, claimed that her husband’s employer’s actions resulted in Mr. Moon’s failure to convert his life insurance to an individual policy following the onset of his disability.  The Fourth Circuit rejected fiduciary breach and equitable estoppel claims for life insurance coverage by Mrs. Moon.  The Court determined that Mrs. Moon failed to establish that the employer was a fiduciary of the life insurance plan because the employer’s alleged failure to alert Mr. Moon that he was no longer covered  under the plan and its continued acceptance of Mr. Moon’s premium payments constituted administrative functions.  Furthermore, the plan was administrated by a third party.  Moon v. BWX Techs., Inc., No. 13-cv-1888, 2014 U.S. App. LEXIS 12525 (4th Cir. July 2, 2014).

See Todd Mobley, Fourth Circuit Rejects Widow’s Claim for Equitable Relief, Mondaq, July 17, 2014.