Court Allows Plaintiff to Pursue Both ERISA Benefit Denial and Fiduciary Duty Claims Against MetLife

In Salhoub v. Metropolitan Life Insurance Company, No. CV 25-2196-KHV, 2025 WL 2938995 (D. Kan. Oct. 16, 2025), the United States District Court for the District of Kansas denied MetLife’s motion to partially dismiss an ERISA lawsuit. The Court ruled that the plaintiff, F. Salhoub, could proceed with both his wrongful denial of benefits claim and a separate claim for breach of fiduciary duty under the Employee Retirement Income Security Act of 1974 (“ERISA”).

Background

Salhoub worked as a financial analyst at Black & Veatch, a company that offered a group long-term disability (“LTD”) plan governed by ERISA. Metropolitan Life Insurance Company (“MetLife”) served as both the insurer and claims administrator for the plan.

In 2021, Salhoub filed a claim for LTD benefits, which MetLife approved for an initial 24-month period ending July 28, 2023. After that period, MetLife denied his claim for continued benefits, asserting that he no longer met the plan’s definition of disability. Salhoub appealed the decision administratively, but MetLife upheld its denial.

On April 15, 2025, Salhoub filed a federal lawsuit alleging two distinct claims:

1. Wrongful denial of benefits under ERISA §502(a)(1)(B), seeking the payment of benefits due under the plan; and
2. Breach of fiduciary duty under ERISA §502(a)(3), seeking equitable relief for MetLife’s alleged procedural violations and failure to act in the best interest of the participant.

MetLife moved to dismiss the fiduciary duty claim, arguing it was duplicative of the benefit denial claim.

Legal Standards

The Court applied the familiar standard under Federal Rule of Civil Procedure 12(b)(6), which requires the complaint to include sufficient factual allegations to “state a claim to relief that is plausible on its face.” Citing Ashcroft v. Iqbal, 556 U.S. 662 (2009) and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), Judge Kathryn H. Vratil reiterated that mere legal conclusions and threadbare recitations of the elements of a cause of action are insufficient.

The Court’s Analysis

The central question was whether Salhoub could pursue both ERISA claims simultaneously. Under §502(a)(1)(B), participants may sue to recover benefits or enforce their rights under the plan. Section 502(a)(3), by contrast, allows participants to seek “appropriate equitable relief” for violations of ERISA or the plan’s terms. The Supreme Court in Varity Corp. v. Howe, 516 U.S. 489 (1996), described §502(a)(3) as a “catchall” provision—a safety net for injuries not adequately addressed elsewhere under ERISA.

MetLife contended that Salhoub’s §502(a)(3) claim was redundant because §502(a)(1)(B) provided an adequate remedy for any denial of benefits. Salhoub responded that he was entitled to plead alternative theories at the early stage of litigation.

The Court agreed with Salhoub. Citing Moyle v. Liberty Mutual Retirement Benefit Plan, 823 F.3d 948 (9th Cir. 2016), N.Y. State Psychiatric Ass’n v. UnitedHealth Group, 798 F.3d 125 (2d Cir. 2015), and Silva v. Metropolitan Life Insurance Co., 762 F.3d 711 (8th Cir. 2014), the Court noted that plaintiffs are permitted to assert both claims at the pleading stage—even if they ultimately cannot recover twice for the same injury.

Judge Vratil emphasized that Salhoub’s fiduciary duty allegations went beyond the mere denial of benefits. Specifically, Salhoub alleged that MetLife failed to follow internal procedures, refused to provide copies of relevant claim documents, and neglected to gather all evidence pertinent to his disability determination. These allegations, the Court held, described breaches of fiduciary duty arising from MetLife’s conduct as plan administrator—not simply from its benefits decision.

The Court’s Decision

Because the Court could not yet determine whether Salhoub’s §502(a)(1)(B) claim would provide a fully adequate remedy, it allowed both claims to proceed. Judge Vratil denied MetLife’s motion to dismiss, concluding that there was “no practical reason to address this issue—which will not impact discovery or any other pretrial matters—at this time.”

The Court also rejected MetLife’s new argument raised in its reply brief—that the complaint’s fiduciary duty allegations were conclusory—because it was raised too late. Even if the Court had considered the argument, it found that Salhoub’s detailed allegations sufficiently described independent fiduciary breaches under ERISA and its implementing regulations.

Takeaway

This decision reaffirms that ERISA plaintiffs may pursue parallel claims for benefits and fiduciary breaches, at least through the pleading stage, when it is unclear whether monetary remedies alone will be sufficient. The ruling underscores that plan administrators, such as MetLife, must follow ERISA’s fiduciary standards and procedural safeguards in claims handling, independent of their ultimate benefits decisions.

For claimants, Salhoub illustrates an important principle: courts will allow alternative ERISA claims to move forward when there is a plausible basis to allege both an improper denial of benefits and a breach of fiduciary duty.