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143401P.pdf 09/03/2015 Yafei Huang v. Life Ins. Co. of North America
U.S. Court of Appeals Case No: 14-3401
U.S. District Court for the Eastern District of Missouri - St. Louis
[PUBLISHED] [Melloy, Author, with Gruender and Benton, Circuit Judges]
Civil case - ERISA. It was reasonable for the plan administrator to find
that delivery of the application to plaintiff during the claims process
satisfied the plan language as she was the insured's personal
representative and the beneficiary of the policy; the express statutory
language in Missouri plainly sets forth delivery of the instrument to the
beneficiary as an alternative, rather than as an additional duty, and
because plaintiff's public-policy/legislative intent argument is contrary
to the plain language, it is rejected; with respect to plaintiff's claim
that she and the insured let another policy lapse based on defendant's
agent's representations, their reliance on the oral representations was
not reasonable; the plan application and summary plan description
adequately and fairly presented the requirements for supplemental
insurance and did not amount to a breach of fiduciary duty; no reasonable
jury could find a breach of fiduciary duty based on the appearance of the
application.