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.)
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