United States District Court, D. Connecticut
LORI T. TYLL, Plaintiff,
STANLEY BLACK & DECKER LIFE INSURANCE PROGRAM and AETNA LIFE INSURANCE COMPANY, Defendant.
RULING ON PARTIAL MOTION TO DISMISS AMENDED
A. BOLDEN UNITED STATES DISTRICT JUDGE.
September 25, 2014, while flying from Paris to New York,
Michael A. Tyll died. Lori Tyll, his wife
(“Plaintiff”), filed this lawsuit, seeking to
recover double indemnity benefits and death and dismemberment
benefits, benefits allegedly owed under the Employee
Retirement Income Security Act of 1974 (“ERISA”).
She alleges that Stanley Black & Decker Life Insurance
Program (“Life Plan”), managed by Defendant
Stanley Black & Decker, Inc. (“Stanley”) and
AETNA Life Insurance Company (“AETNA”)
(collectively, “Defendants”), violated ERISA when
it failed to pay these various life insurance benefits.
now move to dismiss Count III of the Amended Complaint, which
seeks reformation under 29 U.S.C. § 1132(a)(3).
reasons stated below, Defendant's Motion to Dismiss, ECF
No. 33, is GRANTED.
FACTUAL AND PROCEDURAL BACKGROUND
Tyll, allegedly a beneficiary under the Life Plan, is the
executrix and personal representative of the Estate of her
husband, Michael Tyll. Am. Compl. ¶ 1, ECF No. 32. AETNA
is an insurance company organized under the laws of, and
based in, Connecticut. Id. ¶ 2. The Life Plan,
a welfare benefit plan under ERISA, is “an entity,
separate and distinct from its sponsoring company.”
Id. ¶ 3. The Life Plan is located in
Connecticut and intended to provide benefits for the
employees of Defendant Stanley Black & Decker, Inc.
his death, Michael Tyll worked for Stanley Black & Decker
as President of Engineered Fastening. Id. ¶ 8.
As part of his compensation package, Mr. Tyll allegedly
participated in the Life Plan, id. at ¶ 9; Lori
Tyll, his wife, allegedly was a designated beneficiary under
the Life Plan. Id. ¶ 12.
Life Plan “provides life insurance, accidental death
and dismemberment insurance, and business travel insurance
benefits . . . .” See Life Insurance Program,
Plan No. 551 (“Plan”) at 1, Compl., Ex. A, EF No.
32-1. According to the Summary Plan Description,
ECF No. 32-2, the Plan provided coverage if “you die as
a Stanley Black & Decker employee.”
insurance documents stated that “[if] you or your
covered dependent, die or suffer a covered loss . . . the
plan will pay a benefit.” This included “Loss of
Life - including exposure and presumed disappearance.”
Aetna Life Insurance Co. Booklet-Certificate, ECF No. 32-3.
Additionally, if a plan participant died “more than 200
miles from [their] principal place of residence” the
plan would pay to repatriate the participant's remains.
Id. at 21. Finally, the plan stipulated that
individuals who “die solely and as a direct result of
an accident while boarding, alighting from,
or traveling in a public convenience” will qualify for
double indemnity. Id. at 22.
the Schedule of Benefits attached to the Complaint, the Plan
allegedly stipulated that it would pay “150% of your
basic annual earnings, as determined by your employer”
up to a maximum of $1, 000, 000. Schedule of Benefits at 1,
ECF No. 32-4.
Tyll alleges that several provisions of the plan documents
contradict or “fill in the gaps” of the remaining
document. For example, she alleges that, under the Summary
Plan Description, the “Plan Manager” made the
determination of eligibility. Am. Compl. ¶ 52(a). She
also alleges that the Summary Plan Description defines
accidental bodily injury as “exposure to the
elements” and that the documents require the Plan to
pay “one and one-half times annual base pay, ”
where annual base pay is defined as an employee's
“annual base salary.” Id. ¶¶
Mr. Tyll's Death
September 25, 2014, Michael Tyll allegedly traveled to Paris,
France as an employee of Stanley Black & Decker. Am.
Compl. ¶ 21. During his return flight from Paris, Mr.
Tyll died “due to exposure to the elements and other
accidental causes.” Id. ¶ 18. According
to the “determination of a vascular surgeon, Ronald
Nath, M.D., ” “lower air pressure” in the
flight “caused the thrombus to form in Mr. Tyll's
leg” that lead to his death. Id. ¶ 31.
The doctor concluded that “[t]his airline flight caused
Mr. Tyll's death; therefore his death was
flight made an emergency landing in Halifax, Nova Scotia, but
the medical examiner pronounced Mr. Tyll dead when the plane
reached Halifax. Id. ¶ 19. Ms. Tyll alleges
that, as required in the plan, Stanley Black & Decker
paid for repatriation of Mr. Tyll's remains. Id.
Denial of Benefits and Appeal
Tyll allegedly submitted a timely claim for benefits to
AETNA. Am. Compl. ¶ 21. She alleges that, despite clear
language in the Summary Plan Description, the Plan Manager -
Stanley Black & Decker - did not decide her claim.
Id. ¶ 28. Instead, AETNA allegedly denied her
request for benefits on December 23, 2014. Id.