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Tyll v. Stanley Black & Decker Life Insurance Program

United States District Court, D. Connecticut

September 10, 2018

LORI T. TYLL, Plaintiff,



         On 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.

         Defendants now move to dismiss Count III of the Amended Complaint, which seeks reformation under 29 U.S.C. § 1132(a)(3).

         For the reasons stated below, Defendant's Motion to Dismiss, ECF No. 33, is GRANTED.


         Lori 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. Id.

         A. Factual Allegations[1]

         Before 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.

         1. Plan Coverage

         The 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.[2] According to the Summary Plan Description, ECF No. 32-2, the Plan provided coverage if “you die as a Stanley Black & Decker employee.”

         The 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.

         Under 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.

         Ms. 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. ¶¶ 52(b)- (c).

         2. Mr. Tyll's Death

         On 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 accidental.” Id.

         The 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. ¶ 20.

         2. Denial of Benefits and Appeal

         Ms. 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. ...

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