Cisneros
Cisneros v. UNUM Life Insurance Co. of America
Opinion
Lead Opinion
Trott, J.
OVERVIEW
Michelle Cisneros brought this action to recover long-term disability benefits under an ERISA-governed insurance policy (the “Policy”) issued by UNUM Life Insurance Company (“UNUM”). The district court entered summary judgment in favor of UNUM on the ground that Cisneros’s proof-of-claim was untimely under the Policy terms. We agree with the district court’s conclusion that Cisneros failed to comply with the Policy’s unambiguous time-limits for submitting proof-of-claim. However, because we hold that, under California law and federal common law, UNUM is required to show actual prejudice from Cisneros’s untimely submission of proof in order to deny payment, we reverse the judgment in favor of UNUM and remand the case for further proceedings.
BACKGROUND
In 1988, Cisneros worked as an office manager at the Keenan Supply Company, a division of the Hajoca Corporation (“Hajoca”). On August 18, 1988, Cisneros suffered a work-related back injury. As a result of this injury, she has been continuously disabled since June 1992. In March 1994, Cisneros learned that Hajoca provided long-term disability insurance benefits under the Policy and mailed a benefit application to…