Court Rejects Guardian’s Attempt to End ERISA Disability Lawsuit Early

In Rose v. Guardian Life Ins. Co. of Am., No. 8:25-CV-03866-DCC, 2025 WL 2972236 (D.S.C. Oct. 21, 2025), the United States District Court for the District of South Carolina issued a mixed ruling on Guardian’s motion to dismiss and strike in a long-term disability benefits case governed by the Employee Retirement Income Security Act of 1974 (ERISA). The court dismissed several of the plaintiff’s state law and extra-contractual claims as preempted by ERISA but declined to dismiss the ERISA claims at this early stage, allowing the case to proceed.

Background

Plaintiff Rose held a long-term disability policy issued by Guardian Life Insurance Company of America. After becoming permanently disabled, Rose filed a claim and initially received monthly benefits of $10,417. Following an appeal, Guardian corrected his benefit amount to $12,171 but continued to require updated proof of loss through 2024.

Rose alleged ongoing issues with Guardian’s benefit payments and its repeated requests for documentation. He filed suit asserting claims for breach of contract, bad faith, improper claims practices, and violations of ERISA. Guardian moved to dismiss the complaint, arguing that the state law claims were preempted, the ERISA claims were time-barred, and that Rose’s demand for a jury trial and request for punitive and statutory damages should be stricken.

The Court’s Decision

1. State Law Claims Dismissed as Preempted by ERISA

Rose conceded that his state law causes of action were preempted by ERISA. The court accordingly dismissed those claims, leaving only his ERISA-based claims for further review.

2. ERISA Claims Not Time-Barred at the Pleading Stage

Guardian argued that Rose’s ERISA claims were barred by the policy’s contractual three-year limitations period, which began to run following Guardian’s final benefit determination in January 2021. The court declined to dismiss on this basis, finding that it was “unclear from the record” when the limitations period began to run.

Citing Heimeshoff v. Hartford Life & Accident Insurance Co., 571 U.S. 99 (2013), the court recognized that ERISA plans may impose their own reasonable limitations periods, but here, questions of timing and ongoing proof-of-loss requirements through 2024 made dismissal inappropriate. The court emphasized that the statute of limitations defense could not be resolved on the face of the complaint.

3. Statutory Penalty Claim Dismissed

The court dismissed Rose’s claim for statutory penalties under ERISA § 502(c), which applies only to plan administrators. The plan designated Barnes Group, Inc. — not Guardian — as the administrator. Citing cases such as Caffey v. UNUM Life Insurance Co., the court reaffirmed that insurers who merely administer claims cannot be held liable for failure to provide plan documents or information.

4. Punitive and Extra-Contractual Damages Barred

Consistent with Fourth Circuit precedent, the court struck Rose’s request for punitive and extra-contractual damages, holding that ERISA does not authorize such relief. The ruling reiterated that recovery under ERISA is limited to benefits due, enforcement of rights under the plan, or equitable relief.

5. No Right to Jury Trial Under ERISA

Finally, the court granted Guardian’s motion to strike the plaintiff’s jury demand. Citing Berry v. Ciba-Geigy Corp. and other authority, the court noted that ERISA remedies are equitable in nature and thus do not entitle claimants to a jury trial. The case will therefore proceed as a bench trial if it reaches that stage.

Key Takeaways

• ERISA Preemption Is Broad: The court reaffirmed that state law claims for breach of contract and bad faith are preempted by ERISA when the dispute involves a long-term disability policy governed by federal law. Claimants seeking benefits must proceed under ERISA’s framework.
• Statute of Limitations Requires a Factual Record: Guardian argued that the plaintiff’s ERISA claims were untimely under the policy’s three-year contractual limitations period, but the court refused to dismiss at this early stage. The ruling emphasizes that dismissal on limitations grounds is inappropriate where key dates or benefit determinations remain unclear.
• Only Plan Administrators Face ERISA Penalties: The court dismissed the plaintiff’s claim for statutory penalties, noting that such penalties apply only to the plan administrator—not the insurance company—under §502(c). Because the plan named Barnes Group, Inc. as administrator, Guardian could not be held liable.
• No Jury Trial in ERISA Cases: Consistent with long-standing precedent, the court struck the plaintiff’s demand for a jury trial. ERISA claims provide equitable, not legal, remedies, and therefore are decided by a judge rather than a jury.
• Practical Implication for Claimants: Rose underscores the importance of identifying the correct defendant, understanding policy-imposed time limits, and framing claims within ERISA’s procedural rules. Even when insurers like Guardian mishandle disability benefits, recovery depends on compliance with ERISA’s strict legal structure.

How Roberts Disability Law Can Help

If Guardian has denied or underpaid your long-term disability benefits, Roberts Disability Law can help you challenge the decision and protect your rights under ERISA. Our attorneys have extensive experience handling Guardian LTD claims at every stage—from administrative appeals to federal court litigation. We know how Guardian interprets policy terms, handles medical evidence, and applies claim review standards, and we use that insight to build strong, persuasive appeals. Whether your benefits were terminated, delayed, or wrongfully reduced, we can help you navigate the complex ERISA process and fight to recover the benefits you’ve earned.