Sixth Circuit Affirms Denial of Prejudgment Interest and Attorney’s Fees Where the Policy Gave LINA Discretion to Require a Death Certificate as Proof of Loss

Williamson v. Life Insurance Company of North America, No. 25-5790, 2026 WL 3153191 (6th Cir. Oct. 21, 2026) (Before: Kethledge, Chief Judge; Cole and Mathis, Circuit Judges).

In 2013, the insured left Charleston, South Carolina on a fishing vessel that shipwrecked somewhere off the coast of Florida. The Coast Guard found debris from the vessel roughly 22 nautical miles east of Florida and searched for days, but never found the insured, and its investigation listed him as missing. At the time of the shipwreck, an accidental death benefits policy issued by Life Insurance Company of North America (LINA) to American Maritime Officers Plans, a group policyholder, covered the insured. Plaintiff, the curator of the insured’s estate, filed a claim and eventually sued to recover the benefits. LINA ultimately paid the estate $200,000, but the district court denied the estate’s request for prejudgment interest and attorney’s fees and granted summary judgment to LINA on that issue. The Sixth Circuit affirmed.

After the shipwreck, the Coast Guard declined to issue a Letter of Presumed Death and reported only that the insured “remains missing.” The estate supplied the Coast Guard’s and the Florida Fish and Wildlife Conservation Commission’s reports, both of which described the insured as missing. When the estate later claimed benefits, LINA responded that, to process the claim, it required “a finalized death certificate … or other formal document indicating the death.” LINA followed up twice over two months without a response, then notified the estate that it was closing the claim without denying it and invited the estate to reopen it by supplying the requested information. The estate brought this action in 2018.

The court reviewed the grant of summary judgment de novo and the prejudgment interest ruling for abuse of discretion. It held that the district court correctly applied the arbitrary-and-capricious standard to LINA’s proof-of-loss decisions. The policy granted LINA discretion by requiring “[w]ritten or electronic proof of loss satisfactory to Us,” and under circuit precedent a plan confers discretion when it requires proof satisfactory to the insurer. The court rejected the estate’s contention that the district court had improperly applied an arbitrary-and-capricious standard to the prejudgment interest question itself. The district court applied that standard only to LINA’s proof-of-loss and death-certificate decisions, and its conclusion on interest flowed from its finding that LINA had discretion over when to pay. The estate also asked the panel to revisit Perez v. Aetna Life Insurance Co., 150 F.3d 550 (6th Cir. 1998), as wrongly decided, but the panel explained that it had no power to overrule the published decision of a prior panel.

On the merits of prejudgment interest, the court explained that such interest is compensatory, available in the court’s discretion under general equitable principles, and that beneficiaries generally have a right to interest on benefits wrongly withheld. The estate argued that LINA was required to approve the claim immediately and should have investigated the death itself, contending that LINA had enough information to determine that the insured was dead without a death certificate. The court rejected these arguments. LINA had no obligation to investigate because the policy placed the burden of providing satisfactory proof on the claimant. Given the complexities of the claim, including the absence of a death certificate, the district court acted within its discretion in concluding that the estate was not entitled to the benefits earlier than it received them. Because the estate received its benefits timely, it was not entitled to prejudgment interest.

The court also affirmed the denial of attorney’s fees. Because the estate was not entitled to prejudgment interest, it had not shown the “some degree of success on the merits” that Hardt v. Reliance Standard Life Insurance Co., 560 U.S. 242 (2010), requires before a court may award fees under ERISA. The court affirmed the judgment of the district court.