LeGras v. AETNA Life Ins. Co.

Under the Employee Retirement Income Security Act’s federal common law, the deadline to appeal is extended to the following business day when the deadline falls on a Saturday, Sunday, or holiday.

Andre LeGras was seriously injured while working for Federal Express Corporation (“FedEx”). Under his employment for FedEx, LeGras was a beneficiary and participant in FedEx’s Long Term Disability Plan (“Plan”). LeGras initially received disability benefits, but was later informed that his benefits would be terminated. The termination letter provided LeGras with 180 days to appeal the decision, as was the minimum amount of time required under the Employee Retirement Income Security Act (“ERISA”). The 180 day window for appeal expired on a Saturday, and LeGras mailed his appeal on the following Monday. AETNA Life Insurance Company (“AETNA”), the Plan’s Claims Paying Administrator, found LeGras’s appeal to be untimely, and declined to review the appeal. LeGras commenced suit pursuant to the civil enforcement provision of ERISA, to which AETNA responded with a motion for judgment on the pleadings. AETNA argued that LeGras failed to exhaust all administrative remedies by failing to appeal within the deadline, and the district court agreed, granting AETNA’s motion. On appeal, the Ninth Circuit disagreed with the district court, holding that the ERISA’s federal common law should be expanded to allow deadlines to be extended to the next available business day when the deadline falls on a weekend or holiday. Under the expanded common law, the panel found that LeGras’s appeal was timely, and that the district court erred by granting AETNA’s motion. REVERSED and REMANDED.