Stiso v. Intl. Steel Group, 2015 WL 3555917 (6th Cir. June 9, 2015)
Jun 09, 2015OUTCOME: Reversed and Remanded for Award of Benefits
Plaintiff Michael Stiso, an employee of defendant International Steel Group and a beneficiary under its long-term disability insurance plan, brought this action to enforce a 7% per year cost-of-livin ... g increase to his long-term disability benefits. He sought the increase in benefits based on language from the long-term disability plan and from the summary plan description. The language in both the disability plan and in the summary of the disability plan distributed to employees refers to a 7% increase in predisability earnings. The plan, drafted by defendant Metropolitan Life Insurance Company, reads as follows: "Indexed predisability earnings means your predisability earnings increased by 7%. The first increase will take place on the date the 13th monthly Benefit is payable. Subsequent increases will take effect on each anniversary of the first increase. You must have been continually receiving Monthly Benefits under This Plan." Plan at 14. The summary of the plan, distributed to plaintiff by his employer, International Steel, uses similar language regarding “indexed” earnings with a 7% annual increase: "The predisability earnings on which your LTD [long-term disability] replacement income is based are indexed—that is, increased annually by a percentage. After you have received LTD benefits of [sic] 12 months, your predisability earnings are increased by 7%. If you continue receiving LTD benefits, your predisability earnings for purposes of the plan are increased 7% annually on the anniversary of your previous increase." Summary Plan Description at LTD 6-7. [Mr. Stiso] seeks relief under two sections of the Employment Retirement Income Security Act: wrongful denial of benefits under the terms of the insurance plan in violation of Section 502(a)(1)(B), 29 U.S.C.§ 1132(a)(1)(B), and equitable claims of estoppel and breach of fiduciary duty under Section 502(a)(3), 29 U.S.C. § 1132(a)(3). By providing plaintiff with a summary plan description that led plaintiff reasonably to understand that he would receive a 7% yearly increase in benefits and then denying his claim despite the explicit language in the summary plan description, both International Steel and defendant Metropolitan Life Insurance Company breached their fiduciary responsibilities to plaintiff. We therefore reverse the district court’s judgment and remand with instructions to grant an increase in benefits to plaintiff.
