Jane Marie Hall, Plaintiff-Appellant v. Metropolitan Life Insurance Company; Dennis Lynn Hall, Ii, Defendants-Appellees

Summary

The court affirmed summary judgment for MetLife in an ERISA beneficiary dispute. It held that MetLife reasonably determined that the decedent's will did not change the beneficiary and that an unsigned-and-unsubmitted beneficiary form was ineffective because it was not submitted within the plan's thirty-day deadline. The court also held that, even assuming a substantial-compliance doctrine remains available, it cannot override an administrator's discretionary authority to enforce the plan's requirements.