Missed the ERISA Disability Claim Deadline? Court Lets Fiduciary Duty Claim Against Standard Proceed

In Ramos v. Standard Insurance Company, No. 26-cv-01477, 2026 WL 3320290 (N.D. Ill. Nov. 3, 2026), the United States District Court for the Northern District of Illinois dismissed a former machine operator’s claim for ERISA disability benefits because he filed it after the plan deadlines. The court allowed his ERISA claim for equitable relief to proceed against Standard Insurance Company. That claim rests on the theory that Standard breached its fiduciary duty by failing to tell him he was eligible for disability benefits.

What happened in this ERISA disability case?

Plaintiff worked as a machine operator for G&W Electric. Through that job, he participated in a short-term disability program and a group long-term disability plan, both governed by ERISA. Standard administered both plans but paid benefits only under the long-term disability plan. G&W paid the short-term disability benefits.

On or about October 17, 2023, Plaintiff stopped working because of several medical conditions, including gout, tendinopathy of the right bicep, polyarthralgia, osteoarthritis in the right ankle and foot, and asthma. He alleged that these conditions qualified him for benefits under both plans, but he did not know that when he left. He believed workers’ compensation alone would cover his condition. After he learned he might be eligible, he applied for disability benefits on August 21, 2025, nearly two years after he stopped working. Standard did not issue a decision, and Plaintiff filed suit in February 2026. Standard moved to dismiss. Plaintiff then amended his complaint, and the parties agreed that the amendment did not moot the motion.

Both plans set strict deadlines for proof of loss. The short-term plan required proof of loss within ninety days after a five-working-day waiting period if possible, and no later than one year after that ninety-day period. The long-term plan used the same structure with a 180-day waiting period. Both plans stated that unless the claimant lacked capacity, “If Proof Of Loss is filed outside these time limits, your claim will be denied.”

Could Plaintiff recover ERISA disability benefits under the plan terms?

No. Plaintiff sought benefits under 29 U.S.C. § 1132(a)(1)(B). The court explained that courts construe ERISA plan terms strictly, citing Heimeshoff v. Hartford Life & Accident Insurance Co., 571 U.S. 99 (2013), for the principle that contractual limitations provisions “ordinarily should be enforced as written,” especially in ERISA plans.

Standard did not dispute that Plaintiff’s conditions qualified him for benefits. It argued only that he applied too late. Standard calculated his deadlines as January 20, 2024, for the short-term plan and April 14, 2024, for the long-term plan. Plaintiff did not dispute those calculations, did not argue that he lacked capacity, and did not point to any plan provision that would extend his deadline. The court held that his application was untimely under the plan terms and dismissed his claims for legal relief under ERISA.

Did Plaintiff plausibly allege that Standard breached an ERISA fiduciary duty?

Yes. Plaintiff argued that he was entitled to equitable relief because Standard breached its fiduciary duty by failing to inform him of his eligibility. His amended complaint did not expressly plead a fiduciary breach claim. The court nonetheless considered the theory because a plaintiff may elaborate on his allegations in a brief if the elaborations are consistent with the complaint, citing Wigod v. Wells Fargo Bank, N.A., 673 F.3d 547 (7th Cir. 2012), and the court found that Plaintiff’s arguments met that standard.

Under Kenseth v. Dean Health Plan, Inc., 610 F.3d 452 (7th Cir. 2010), a fiduciary breach claim requires that the defendant be a plan fiduciary, that it breached its duty, and that the breach harmed the plaintiff. The court found the first and third elements easily satisfied. As plan administrator with discretionary authority, Standard qualified as a fiduciary under 29 U.S.C. § 1002(21)(A). If Standard breached its duty, that breach harmed Plaintiff by causing him to miss his filing deadlines and potentially lose more than $100,000 in benefits.

On the breach element, the court relied on the fiduciary duty to disclose material information. It quoted Eddy v. Colonial Life Insurance Co. of America, 919 F.2d 747 (D.C. Cir. 1990), which described that duty as “the core of a fiduciary’s responsibility.” It also quoted Kalda v. Sioux Valley Physician Partners, Inc., 481 F.3d 639 (8th Cir. 2007), which the Seventh Circuit cited with approval in Kenseth v. Dean Health Plan, Inc.: a fiduciary “cannot remain silent if it knows or should know that the beneficiary is laboring under a material misunderstanding of plan benefits.” The court also cited Bixler v. Central Pennsylvania Teamsters Health & Welfare Fund, 12 F.3d 1292 (3d Cir. 1993), which recognized the gap in training and knowledge between a lay beneficiary and a trained fiduciary. The court acknowledged limits on the duty as well. Under Chojnacki v. Georgia-Pacific Corp., 108 F.3d 810 (7th Cir. 1997), ERISA does not require administrators to investigate every participant’s circumstances.

The court identified the key question as whether Standard knew or should have known that Plaintiff was eligible or potentially eligible for benefits. If so, Standard likely had a duty to tell him about his eligibility and the application deadlines. The court noted that this was especially true because Plaintiff worked as a laborer, alleged that he was not sophisticated in insurance or benefits matters, and may have faced a language barrier. If Standard had no reason to suspect he was leaving work with qualifying conditions, it likely had no duty to inform him.

The amended complaint did not directly allege that Standard knew about Plaintiff’s conditions. Drawing reasonable inferences in his favor, however, the court found that the allegations supported that inference. Plaintiff alleged that he expected workers’ compensation to cover his condition, that his conditions stemmed from a workplace injury, and that Standard never sent him claim forms. If he received workers’ compensation, G&W at least knew about his conditions. If Standard administered G&W’s workers’ compensation, Standard knew as well. Even if it did not, the court found it reasonable to infer that G&W told Standard, because G&W paid short-term disability benefits and likely communicated regularly with Standard about its obligations under that plan.

The court also noted that what Standard knew, and when it knew it, concerns Standard’s state of mind, which courts usually do not resolve on a motion to dismiss, citing Air Line Pilots Association, International v. Department of Aviation of City of Chicago, 45 F.3d 1144 (7th Cir. 1995). The court held that Plaintiff plausibly alleged that Standard breached its fiduciary duty.

Could Plaintiff pursue equitable relief against Standard for the short-term disability plan?

Yes. Standard argued that it could not be liable for short-term disability benefits because G&W, not Standard, paid them. Standard relied on Brooks v. Pactiv Corp., 729 F.3d 758 (7th Cir. 2013), which requires a claim for benefits to be brought against the party obligated to pay them. The court explained that this argument related only to legal relief for benefits, which it had already dismissed. It had no bearing on whether Standard breached a fiduciary duty as administrator of the short-term plan. The court found it premature to dismiss those equitable claims.

What did the court decide?

The court granted the motion to dismiss in part and denied it in part. It dismissed Plaintiff’s claims for legal relief under ERISA against Standard and allowed his claims for equitable relief under ERISA against Standard to proceed.