Plaintiff Glee Fleet seeks payment of disability benefits and waiver of life insurance premiums under her employee benefit plan. The Independent Federal Credit Union Benefit Plan ("Benefit Plan" or "the Plan") provided disability and life insurance coverage, among other benefits, to employees of Fleet's employer, the Independent Federal Credit Union ("IFCU"). The Benefit Plan was underwritten by CUNA Mutual Insurance Society ("CUNA"). Fleet was vice president of Human Resources and Operations at the IFCU. She both administered and participated in the Plan. The Benefit Plan and the case are governed by the Employee Retirement Income Security Act ("ERISA"), 29 U.S.C. 1001 et seq. Fleet alleges that the defendant Benefit Plan wrongfully denied short term and long term disability benefits and wrongfully terminated life insurance benefits for which she was eligible.
The Plan has moved to dismiss Fleet's claims of wrongful denial of long term disability benefits and wrongful termination of life insurance benefits, and to remand the case to CUNA for exhaustion of administrative remedies. The defendant's theory is that it made a final decision only as to Fleet's eligibility for short term disability benefits, and that it has not yet determined whether she is entitled to long term disability benefits and a life insurance premium waiver, so that there is no administrative record relating to those claims. The defendant's motion relies on the well-established rule that a district court has discretion to require exhaustion of administrative remedies before considering an ERISA claim for benefits.