Conley v. Pitney Bowes
United States Court of Appeals for the Eighth Circuit
34 F.3d 714 (8th Cir. 1994)
In Conley’s (plaintiff) employment contract with Pitney Bowes (defendant), Conley was required to exhaust all administrative procedures before bringing suit against Pitney Bowes on an ERISA claim. However, the contract also provided that any notice of denial of Conley’s benefits must also include instructions about the appeal procedures. Pitney Bowes sent Conley a letter denying his benefits, but the letter did not contain any information about appeal procedures, including the requirement of exhaustion of administrative procedures. Without exhausting administrative appeal procedures, Conley brought suit against Pitney Bowes, claiming improper denial of benefits. The district court awarded summary judgment to Pitney Bowes, ruling that Conley had a summary plan book and so must have known of the administrative procedures. Conley appealed.
Rule of Law
Holding and Reasoning (Arnold, J.)
Dissent (Gibson, S.J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 177,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.