District Court Affirms Widow’s ERISA Claim Against Dell, Dismisses MetLife from Life Insurance Coverage Dispute

In Avila v. Metropolitan Life Insurance Company & Dell Inc., No. 1:24-CV-0242-DAE, 2025 WL 1663104 (W.D. Tex. June 12, 2025), Texas Western District Senior Judge David Alan Ezra issued a mixed ruling on Defendants’ motion to dismiss in an ERISA dispute involving a denied life insurance claim. While the Court granted Defendant MetLife’s motion to dismiss entirely, it denied Defendant Dell Inc.’s effort to escape fiduciary liability under ERISA Section 502(a)(3), allowing the claim against the employer to proceed. The case underscores key distinctions in fiduciary obligations between plan administrators and insurers under ERISA and illustrates how “special circumstances” can sustain breach of fiduciary duty claims even in the absence of participant-initiated inquiries.

Plaintiff Lorenza Avila brought suit under ERISA § 502(a)(1)(B) and § 502(a)(3) after her husband, Arseny Lepiavka, died, without valid life insurance coverage, despite previously being covered under Dell’s group life policy administered by MetLife. Lepiavka’s coverage purportedly lapsed on December 31, 2019, yet Avila alleged that neither she nor her husband received any notice from Dell or MetLife about the need to port or convert the policy.

MetLife denied the life insurance claim, asserting that it mailed a conversion notice in November 2019 and followed up with voicemails. Avila, however, denied receipt of either the letter or voicemails. She sued to recover $775,000 in benefits and asserted fiduciary breach claims against both defendants. Magistrate Judge Hightower recommended partially dismissing the case, and Judge Ezra largely adopted the recommendation—dismissing MetLife from the case while allowing Avila’s claim against Dell to proceed.

The Court granted MetLife’s motion to dismiss, agreeing that Avila failed to state a claim for wrongful denial of benefits under § 502(a)(1)(B) and rejecting her fiduciary breach claim under § 502(a)(3). MetLife successfully argued that, as claims administrator, it lacked a fiduciary obligation to notify plan participants of their right to port or convert coverage—particularly when such a duty was not expressly imposed by the Plan terms.

The Court emphasized that ministerial tasks such as sending conversion notices generally do not constitute fiduciary acts. However, the decision acknowledged a nuanced point: when MetLife voluntarily chose to issue such notices, it arguably exercised discretionary authority. Yet, the Court ultimately found no basis to conclude that MetLife acted as a fiduciary or breached any duties under ERISA absent a clear mandate or individualized knowledge of Lepiavka’s medical status.

By contrast, the court denied Dell’s motion to dismiss. While Dell argued that ERISA fiduciary duties arise only upon participant-initiated inquiries (as articulated by the Fifth Circuit in Switzer v. Wal-Mart Stores, Inc., 52 F.3d 1294 (5th Cir. 1995)), the Court determined that Avila plausibly alleged “special circumstances” that could trigger an affirmative duty to inform pursuant to the Fifth Circuit’s holdings in Ehlmann v. Kaiser Found. Health Plan of Tex., 198 F.3d 552 (5th Cir. 2000), and Martinez v. Schlumberger, Ltd., 338 F.3d 407 (5th Cir. 2003).

Specifically, Dell—unlike MetLife—was both plan administrator and employer, and the record suggested it was well aware of Lepiavka’s cancer and disability leave, which lasted two years. Avila alleged that Dell’s human resources coordinated medical leave, and even CEO Michael Dell was personally aware of Lepiavka’s illness. These factual assertions, if true, could show Dell knew that a failure to notify Lepiavka of conversion rights would materially affect his family’s access to coverage.

If MetLife or your life insurer has denied your ERISA benefits claim, contact us for assistance.