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Louisiana District Court Rules that Claimant’s Access to Prudential’s Claim File Required for a “Full and Fair Review” under ERISA

The Case

Natasha LeJeune sought optional life insurance benefits from Prudential Insurance Company of America (“Prudential”), which were denied. Ms. LeJeune filed suit under ERISA. Prudential argued that Ms. LeJeune failed to exhaust her administrative remedies, a requirement under ERISA before being able to file a lawsuit.

According to Ms. LeJeune, Prudential denied her a “full and fair review” by failing to provide her with a copy of the claim file despite multiple written requests from her attorneys. Prudential did provide the claim file, but not until after Ms. LeJeune filed a lawsuit in federal court and until after the appeal deadline had passed. Ms. LeJeune also argued that, because she did not receive a “full and fair review”, her administrative remedies should be deemed exhausted because it was Prudential’s fault she was unable to timely appeal.

The court found that Prudential’s failure to provide Ms. LeJeune with the entire claim file prevented her from a reasonable opportunity for a “full and fair review” as required by ERISA. Accordingly, the court remanded the case back to Prudential for a decision.

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