Guidry v. Metropolitan Life Insurance Company et al

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UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
KATHERINE CROW ALBERT GUIDRY, 	CIVIL ACTION
INDIVIDUALLY AND ON BEHALF OF
THE ESTATE OF JASON PAUL GUIDRY
VERSUS
25-18-SDD-RLB
METROPOLITAN LIFE INSURANCE
COMPANY, ET AL
RULING
The Court takes up several motions in this ERISA case: 1) Life Insurance Company
of North America’s (“LINA”) Motion for Partial Summary Judgment on the Issue of ERISA
Preemption; 1 	2) 	Metropolitan 	Life 	Insurance 	Company’s 	(“MetLife”) 	and 	Waste
Management 	National 	Services, 	Inc.’s 	(“Waste 	Management”) 	Motion 	for 	Partial
Summary Judgment; 2 3) Waste Management’s Motion for Judgment on the Administrative
Record; 3 and 4) MetLife’s Motion for Judgment on the Administrative Record. 4 The parties
have filed their Briefs on the Merits5 in accordance with the ERISA Case Order. Waste
Management and MetLife additionally moved for, and were granted, leave to file Reply
briefs on their Motions for Judgment on the Administrative Record. 6 Also pending are two
Motions to Dismiss pursuant to Federal Rule of Civil Procedure (“Rule”) 12(b)(6) filed by
Waste Management and MetLife, respectively. 7
1 Rec. Doc. 40.
2 Rec. Doc. 44.
3 Rec. Doc. 65.
4 Rec. Doc. 66.
5 Rec. Docs. 64, 65, 66, 67.
6 Rec. Docs. 74, 75.
7 Rec. Docs. 17, 18.
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For the reasons that follow, the Motions for Summary Judgment and Motions for
Judgment on the Administrative Record will be granted, Plaintiff’s claims against all
Defendants will be dismissed, and the Motions to Dismiss will be terminated as moot.
I. 	FACTUAL AND PROCEDURAL BACKGROUND
Plaintiff, Katherine Crow Albert Guidry (“Plaintiff”), initiated this action to recover
allegedly unpaid life insurance proceeds in relation to her deceased husband, Jason
Guidry. 8 Plaintiff alleges that she and Jason Guidry, through Waste Management (Jason
Guidry’s employer), entered into a contract of life insurance with MetLife.9 According to
Plaintiff’s Complaint, after Jason Guidry’s death on January 9, 2024, “[t]he defendants
engaged in conduct to deny the decedent and his wife, petitioner (beneficiary) herein to
collect on the policy proceeds by creating a confusing chain of events to disqualify the
decedent from the rights he secured prior to his cancer diagnosis to prohibit the
decedent’s beneficiary’s ability to collect on the policy of insurance.” 10 Plaintiff specifically
alleges that $504,000 in Optional Life Insurance coverage was wrongfully withheld. 11
Plaintiff’s Complaint cites the Employee Retirement Income Security Act (ERISA) as well
as three Louisiana statutes: La. R.S. 22:656, La. R.S. 22:176, and La. R.S. 22:1811. 12
The Magistrate Judge entered an ERISA Case Order in this matter which, inter
alia, ordered the parties to “file a (1) joint stipulation, or (2) a motion for summary judgment
or other dispositive motion as to the following issues: a. whether the plan vests the
administrator with discretionary authority to determine eligibility for benefits and/or
8 Rec. Doc. 1.
9 Id. at ¶ IV.
10 Id. at ¶¶ VI, X.
11 Id. at ¶¶ VII, VIII
12 Id. at ¶ II.
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construe and interpret the terms of the plan; and b. whether ERISA preempts all state law
claims related to the employee benefit plan at issue.” 13 The parties did not reach
stipulations on these issues. Waste Management and MetLife filed a joint Motion for
Summary Judgment on the first issue (whether the plan vests the administrator with
discretionary authority) 14 and LINA filed a Motion for Summary Judgment on the second
issue (ERISA preemption). 15
Waste Management and MetLife jointly filed copies of the Waste Management
Health and Welfare Benefits Plan (the “Plan”), the Summary Plan Description (“SPD”),
and the administrative record concerning Plaintiff’s claim for benefits.16 LINA filed its
administrative record as well as copies of an Administrative Services Agreement between
LINA 	and 	Waste 	Management. 17 	Plaintiff 	stipulated 	to 	the 	completeness 	of 	the
administrative record.18
In accordance with the ERISA Case Order, Plaintiff filed her Opening Brief on the
Merits on October 15, 2025. 19 Waste Management and MetLife subsequently filed
separate Response Briefs on the Merits, within which they also asserted Motions for
Judgment on the Administrative Record 20 seeking dismissal of all claims brought against
them. LINA filed a Response Brief on the Merits seeking dismissal of Plaintiff’s claims. 21
Plaintiff filed separate Replies to all three of the Defendants’ filings. 22
13 Rec. Doc. 32, ¶ II.
14 Rec. Doc. 44.
15 Rec. Doc. 40.
16 Rec. Doc. 47.
17 Rec. Doc. 35.
18 Rec. Doc. 54.
19 Rec. Doc. 64.
20 Rec. Docs. 65, 66.
21 Rec. Doc. 67.
22 Rec. Docs. 68, 69, 70.
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II. 	LAW AND ANALYSIS
A. Motions for Summary Judgment
1. 	Legal Standard
In reviewing a party’s motion for summary judgment, the Court will grant the motion
if (1) there is no genuine issue of material fact, and (2) the mover is entitled to judgment
as a matter of law. 23 This determination is made “in the light most favorable to the
opposing party.”24 “When seeking summary judgment, the movant bears the initial
responsibility of demonstrating the absence of a genuine issue of material fact with
respect to those issues on which the movant bears the burden of proof at trial.” 25 If the
moving party satisfies its burden, “the non-movant must respond to the motion for
summary judgment by setting forth particular facts indicating that there is a genuine issue
for 	trial.”26 	However, 	the 	non-moving 	party’s 	burden 	“‘is 	not 	satisfied 	with 	some
metaphysical doubt as to the material facts, by conclusory allegations, by unsubstantiated
assertions, or by only a scintilla of evidence.’”27
Notably, “[a] genuine issue of material fact exists, ‘if the evidence is such that a
reasonable jury could return a verdict for the nonmoving party.’” 28 All reasonable factual
inferences are drawn in favor of the nonmoving party. 29 However, “[t]he Court has no duty
23 FED. R. C IV . P. 56(a).
24 Adickes v. S. H. Kress & Co., 398 U.S. 144, 157 (1970) (citing United States v. Diebold, Inc., 369 U.S.
654, 655 (1962); 6 V. MOORE , FEDERAL PRACTICE 56.15(3) (2d ed. 1966)).
25 Transamerica Ins. Co. v. Avenell, 66 F.3d 715, 718 (5th Cir. 1995) (citing Celotex Corp. v. Catrett, 477
U.S. 317, 333–34 (1986)).
26 Byers v. Dallas Morning News, Inc., 209 F.3d 419, 424 (5th Cir. 2000) (citing Anderson v. Liberty Lobby,
Inc., 477 U.S. 242, 248–49 (1986)).
27 Willis v. Roche Biomedical Lab., Inc., 61 F.3d 313, 315 (5th Cir. 1995) (quoting Little v. Liquid Air Corp.,
37 F.3d 1069, 1075 (5th Cir. 1994)).
28 Pylant v. Hartford Life and Accident Ins. Co., 497 F.3d 536, 538 (5th Cir. 2007) (quoting Anderson, 477
U.S. at 248)).
29 Galindo v. Precision Am. Corp., 754 F.2d 1212, 1216 (5th Cir. 1985).
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to search the record for material fact issues. Rather, the party opposing the summary
judgment is required to identify specific evidence in the record and to articulate precisely
how this evidence supports his claim.” 30 “Conclusory allegations unsupported by specific
facts . . . will not prevent an award of summary judgment.”31
2. 	Waste Management’s and MetLife’s Motion for Summary Judgment
The Supreme Court directs courts to conduct de novo review when adjudicating
ERISA benefit disputes unless the plan documents give “the administrator or fiduciary
discretionary authority to determine eligibility for benefits or to construe the terms of the
plan.” 32 Where the plan administrator has discretionary authority to determine eligibility
for benefits or to construe the terms of the plan, courts must base their review of the legal
and 	factual 	findings 	of 	the 	administrator's 	decision 	under 	an 	abuse 	of 	discretion
standard. 33
Pursuant to the ERISA Case Order, because there was no stipulation reached on
this issue, Waste Management and MetLife move for summary judgment that the
employee welfare benefits plan at issue in this case gives the administrator discretionary
authority to determine eligibility for benefits and to construe the terms of the Plan. Under
the Plan, the “Administrator” is “the Administrative Committee of the Waste Management
Employee Benefits Plans, which is the ‘Plan Administrator’ of the Plan, as such term is
defined under Section 3(16) of ERISA.” 34 The Plan further provides: “The Administrator
may also mean any other individual or entity designated from time to time by the
30 RSR Corp. v. Int’l Ins. Co., 612 F.3d 851, 857 (5th Cir. 2010) (citing Ragas v. Tenn. Gas Pipeline Co.,
136 F.3d 455, 458 (5th Cir.1998)).
31 Nat’l Ass’n of Gov’t Emps. v. City Pub. Serv. Bd. of San Antonio, Tex., 40 F.3d 698, 713 (5th Cir. 1994).
32 Firestone Tire and Rubber Co. v. Bruch, 489 U.S. 101, 115 (1989).
33 See Vercher v. Alexander & Alexander Inc., 379 F.3d 222, 226 (5th Cir. 2004).
34 Rec. Doc. 47-5, p. 7.
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Administrator.”35 In Article XI, the Plan provides that the Administrator shall have certain
“express discretionary authorities,” including “to construe and interpret the terms of the
Plan, and to resolve all ambiguities, inconsistencies or omissions therein,” and “to decide
all questions of eligibility and determine the amount, manner and time of payment of any
benefits” under the Plan.36
Additionally, the Plan gives the Administrator “the power to delegate specific duties,
discretionary and other authorities, and responsibilities to officers or Employees of the
Company or other individuals or entities.” 37 The Administrator is permitted “to appoint or
name a Claims Administrator to handle the administration of claims.” 38 Article XII of the
Plan, entitled “Claims Administration,” provides in part:
The 	Administrator 	may 	delegate 	its 	authority 	and
responsibilities under this Article to a Claims Administrator,
provided such delegation is in writing. Any reference to
Administrator in this Article shall mean the applicable Claims
Administrator if the relevant authority and responsibility has
been 	delegated 	by 	the 	Administrator 	to 	that 	Claims
Administrator. 	The 	Administrator 	has 	sole 	discretionary
authority to grant or deny benefits under the Plan. Benefits
under the Plan shall be paid only if the Administrator decides
in its sole discretion that the Claimant is entitled to them.39
The Court finds that the Plan clearly vests the Administrator with discretionary
authority to determine eligibility for benefits and to construe the terms of the plan.
Plaintiff’s Opposition is meritless and provides no evidence to contradict the express
terms of the Plan quoted above. Therefore, the Motion will be granted. Because the Plan
35 Id.
36 Id. at p. 56.
37 Id. at p. 57.
38 Id.
39 Id. at p. 58.
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gives the Administrator discretionary authority, the abuse of discretion standard of review
applies in this matter.
3. 	LINA’s Motion for Summary Judgment
LINA’s Motion relates to the second issue identified in the ERISA Case Order:
whether ERISA preempts all state law claims related to the Plan. In her Complaint, Plaintiff
cites three Louisiana statutes: La. R.S. 22:656; La. R.S. 22:176; and La. R.S. 22:1811. 40
In connection with these citations, Plaintiff alleges that the Defendants arbitrarily and
capriciously failed to pay her claim for Employee Optional Life Insurance coverage
following the death of Jason Guidry. 41 In addition to “general and special damages,”
Plaintiff demands penalties and attorney’s fees. 42
Section 514(a) of ERISA provides that ERISA “shall supersede any and all State
laws insofar as they may now or hereafter relate to any employee benefit plan[.]” 43 In
general, a state law “relates to” an ERISA plan “whenever it has ‘a connection with or
reference to such a plan.’” 44 According to the Fifth Circuit, state law causes of action are
barred under Section 514(a) “if (1) the state law claim addresses an area of exclusive
federal concern, such as the right to receive benefits under the terms of an ERISA plan;
and (2) the claim directly affects the relationship between the traditional ERISA entities—
the employer, the plan and its fiduciaries, and the participants and beneficiaries.”45 “The
language of the ERISA preemption clause is deliberately expansive, and has been
40 See Rec. Doc. 1, ¶ XIV.
41 Id.
42 Id.
43 29 U.S.C. § 1144(a).
44 Hubbard v. Blue Cross & Blue Shield Ass'n, 42 F.3d 942, 945 (5th Cir.1995) (quoting Corcoran v. United
Healthcare, Inc., 965 F.2d 1321, 1328–29 (5th Cir.1992), abrogated on other grounds by Mertens v. Hewitt
Assoc., 508 U.S. 248 (1993)).
45 Id. (citing Weaver v. Employers Underwriters, Inc., 13 F.3d 172, 176 (5th Cir.1994); Memorial Hosp.
System v. Northbrook Life Ins. Co., 904 F.2d 236, 245 (5th Cir.1990)).
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construed broadly by federal courts.”46 The Supreme Court has held that ERISA preempts
state law tort and contract claims for improper processing of a claim for benefits.47
Plaintiff notes that the Short-Term Disability program under the Plan “is not subject
to ERISA.” 48 However, Plaintiff has not asserted a claim for Short-Term Disability benefits
in this lawsuit. Rather, Plaintiff seeks to recover Employee Optional Life Insurance
benefits, to which ERISA does apply.49
La. R.S. 22:1811 provides: “All death claims arising under policies of insurance
issued or delivered within this state shall be settled by the insurer within sixty days after
the date of receipt of due proof of death, and if the insurer fails to do so without just cause,
the amount due shall bear interest at the rate of eight percent per annum from date of
receipt of due proof of death by the insurer until paid.” Courts have repeatedly recognized
that these types of claims are preempted by ERISA. 50 Because Plaintiff’s claim under La.
R.S. 22:1811 addresses an area of exclusive federal concern and directly affects the
relationship between traditional ERISA entities, the claim will be dismissed as preempted
by ERISA.
46 Id.
47 Pilot Life Ins. Co. v. Dedeaux, 481 U.S. 41, 57 (1987).
48 Rec. Doc. 47-3, p. 114
49 Id. at p. 167 (“The Waste Management Health and Welfare Benefits Plan is governed by ERISA [ ]. Note,
however, that the Short-Term Disability Program, the Adoption Assistance Program, the LegalZoom
LifePlan and the Dependent Day Care Flexible Spending Account Program are not subject to ERISA.”).
50 See, e.g., Wright v. Louisiana Corrugated Products, LLC, 59 F.Supp.3d 767 (W.D. La. 2014) (“Courts
consistently have recognized that ERISA preempts a claim for unpaid benefits, penalties, and fees under
Louisiana Revised Statute § 22:657 (now § 22:1821).”); Hartford Life & Accident Ins. Co. v. Varnado, No.
CV 16-00015-SDD-EWD, 2016 WL 2354539, at *3 n.14 (M.D. La. Mar. 24, 2016), report and
recommendation adopted, No. CV 16-15-SDD-EWD, 2016 WL 1746055 (M.D. La. May 2, 2016) (claim
under La. R.S. 22:1811 (formerly cited at La. R.S. 22:656) would be preempted under ERISA); James v.
Connecticut Gen. Life Ins. Co., No. CIV.A. 07-799-B-M2, 2010 WL 3724514, at *4 (M.D. La. Aug. 5, 2010),
report and recommendation adopted, No. CIV.A. 07-799-FJP-CN, 2010 WL 3724513 (M.D. La. Sept. 14,
2010) (same). See also Hansen v. Cont'l Ins. Co., 940 F.2d 971, 979 (5th Cir. 1991) (“In short, when
beneficiaries seek to recover benefits from a plan covered by ERISA, their exclusive remedy is provided by
ERISA, in 29 U.S.C. § 1132(a)(1)(B).”); Anderson v. Bus. Men's Assur. Co., No. CIV.A. 02-2212, 2003 WL
21305335, at *9 (E.D. La. June 5, 2003) (La. R.S. 22:656 (now numbered as La. R.S. 22:1811) preempted
by ERISA).
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Plaintiff also purports to lodge claims under La. R.S. 22:656 and La. R.S. 22:176
but fails to explain how these statutes could afford any relief under the circumstances
presented in this action. Plaintiff additionally fails to explain why any such action would
not be preempted by ERISA. The Court finds these statutes wholly inapplicable to the
allegations in this case. Even if the statutes were somehow applicable, Plaintiff has not
articulated any state law claims that would not be preempted.51
For the foregoing reasons, Plaintiff’s state law claims will be dismissed as
preempted by ERISA.
B. Parties’ Briefs on the Merits
1. 	Plaintiff’s Brief
Without any citation to the administrative record, Plaintiff in her Opening Brief on
the Merits asserts that Jason Guidry “was not accorded all of his vacation time and Family
Medical Leave Extended Time that allowed him to be classified, according to the Plan
Administrators, as ‘actively at work’” as required under the Plan for entitlement to Optional
Life Insurance coverage. 52 Plaintiff maintains that “Defendants did not exercise their duty
to maximize [Plaintiff’s] benefits by maintaining [Plaintiff’s] employment status, which they
had a fiduciary duty to do under the [P]lan.” 53 In short, Plaintiff alleges that she and Jason
Guidry were misled by Defendants as follows:
Petitioner and her deceased spouse were led to believe,
intentionally 	or 	by 	negligent 	misrepresentation, 	that 	they
would be better off if he sought to seek status for leave and/or
(short term) temporary disability. They were not advised that
receiving a leave status or temporary disability status would
51 La. R.S. 22:1811 was previously numbered as La. R.S. 22:656. To the extent Plaintiff’s reference to La.
R.S. 22:656 was meant to refer to the statute now found at La. R.S. 22:1811, the claim is preempted as
explained.
52 Rec. Doc. 64, p. 2.
53 Id.
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result in loss of the death benefits from the $500,000.00
policy. No attempt was made by the defendants to allow all
vacation and family leave time to be applied before placing
him on temporary disability. 54
Plaintiff’s Brief contains no legal citations.
2. 	Liability of Waste Management
The Court finds that Plaintiff has no claim against Waste Management. Section
502(a)(1)(B) of ERISA allows a claimant to bring a civil action “to recover benefits due to
him under the terms of his plan, to enforce his rights under the terms of the plan, or to
clarify his rights to future benefits under the terms of the plan.”55 Waste Management was
Jason Guidry’s employer. The Fifth Circuit has found that “a claimant may bring a suit
against an employer when the plan has no meaningful existence apart from the employer,
and when the employer made the decision to deny benefits.”56 As stated in the SPD in
this case, “Life and AD&D” coverages are “fully-insured,” meaning that “[a]n insurance
carrier provides administrative services and makes decisions regarding benefits. The
insurance 	carrier 	insures 	coverages 	and 	makes 	benefit 	payments.”57 	MetLife 	is
designated as the Claims Administrator for Life and AD&D coverages. 58 The record shows
that 	MetLife, 	not 	Waste 	Management, 	denied 	Plaintiff’s 	claim 	for 	Optional 	Life
Insurance. 59 	Thus, the documents show that Waste Management did not make the
decision to deny Optional Life Insurance benefits, and Plaintiff has pointed to no record
54 Id. at p. 7.
55 29 U.S.C. § 1132(a)(1)(B).
56 LifeCare Mgmt. Servs. LLC v. Ins. Mgmt. Adm'rs Inc., 703 F.3d 835, 843 (5th Cir. 2013) (citing Musmeci
v. Schwegmann Giant Super Markets, Inc., 332 F.3d 339, 349–50 (5th Cir.2003)).
57 Rec. Doc. 47-3, p. 5. See also id. at p. 169 (“…the insurance companies have sole discretionary authority
to grant or deny benefits under insured plans, and to make benefit determinations in accordance with the
terms of the policies they have issued to [Waste Management].”).
58 Id. at p. 168.
59 Rec. Doc. 47-1, p. 50.
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evidence supporting a cause of action against Waste Management. Accordingly, the Court
will grant Waste Management’s Motion for Judgment on the Administrative Record.
3. 	Liability of MetLife
Plaintiff’s claim against MetLife also lacks merit. As established, MetLife as Claims
Administrator had discretionary authority to interpret the terms of the policy and to make
benefit eligibility determinations on claims for life insurance. 60 Thus, the Court reviews
MetLife’s decision for abuse of discretion. 61 “In the context of ERISA, the abuse of
discretion standard of review ‘is the functional equivalent of arbitrary and capricious
review.’” 62 Review of this question is limited to the record that was before MetLife at the
time of the final claim decisions. 63 If MetLife’s decision “is supported by substantial
evidence and is not arbitrary or capricious, it must prevail.” 64 “Substantial evidence is
more than a scintilla, less than a preponderance, and is such relevant evidence as a
reasonable mind might accept as adequate to support a conclusion.” 65 MetLife’s decision
is only deemed arbitrary “‘if made without a rational connection between the known facts
and the decision or between the found facts and the evidence.’” 66 Under the abuse of
discretion standard, a court's “‘review of the administrator's decision need not be
60 Rec. Doc. 47-5, pp. 56–58; Rec. Doc. 47-3, pp. 168–169.
61 See Vercher, 379 F.3d at 226.
62 Tesch v. Prudential Ins. Co. of America, 829 F.Supp.2d 483, 493 (W.D. La. 2011) (quoting Anderson v.
Cytec Industries, Inc., 619 F.3d 505, 512 (5th Cir. 2010)).
63 See Vega v. Nat'l Life Ins. Servs., 188 F.3d 287, 299-300 (5th Cir. 1999) (abrogated on other grounds).
64 Schexnayder v. Harford Life & Acc. Ins. Co., 600 F.3d 465, 468 (5th Cir. 2010) (quoting Ellis v. Liberty
Life Assurance Co. of Boston, 394 F.3d 262, 273 (5th Cir. 2004)).
65 Rittinger v. Healthy Alliance Life Insurance Company, 914 F.3d 952, 957 (5th Cir. 2019) (citations omitted)
(internal quotation marks omitted).
66 Meditrust Fin. Servs. Corp. v. Sterling Chems., Inc., 168 F.3d 211, 215 (5th Cir. 1999) (quoting Bellaire
Gen. Hosp. v. Blue Cross Blue Shield, 97 F.3d 822, 828–29 (5th Cir.1996)).
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particularly complex or technical; it need only assure that the administrator's decision falls
somewhere on a continuum of reasonableness — even if on the low end.’” 67
The Plan provides both “Basic Employee Life and AD&D,” as well as “Optional
Employee Life and AD&D.” 68 According to the SPD, “[t]he Company [Waste Management]
automatically provides [the employee] with basic employee life and AD&D coverage.” 69
With respect to the optional coverage, the SPD further provides: “In addition to the
Company-provided basic employee life and AD&D coverage, you may purchase optional
employee life and AD&D coverage for yourself. This coverage provides additional
protection to your beneficiary in the event of your death.”70 The employee may purchase
up to eight times his annual pay in Optional Employee Life and AD&D. 71 An employee
may select optional coverage when he is first hired and each year during annual
enrollment. 72 The SPD states:
If you elect to increase your optional coverage during annual
enrollment, you must be actively at work on January 1 (the
first day of the plan year) for any increase in coverage to take
effect. If you are not actively at work on that date, the change
in your benefits will take place when you return to active
work. 73
According to the SPD, “[a]ctively at work means you are performing all of the material
duties 	of 	your 	job 	with 	[Waste 	Management] 	where 	these 	duties 	are 	normally
performed.” 74
67 Corry v. Liberty Life Assurance Co. of Boston, 499 F.3d 389, 398 (5th Cir. 2007).
68 Rec. Doc. 47-3, p. 98.
69 Id. at p. 97.
70 Id.
71 Id. at p. 98.
72 Id. at p. 99.
73 Id. at p. 103.
74 Id. at p. 10.
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The record reveals the following pertinent facts. On January 16, 2024, Plaintiff
submitted a claim to MetLife for life insurance benefits payable on the life of Jason Guidry
under the Plan. 75 Plaintiff transmitted Jason Guidry’s death certificate to MetLife, which
reflected January 9, 2024, as the date of death. 76 On February 27, 2024, MetLife paid
Plaintiff $63,018.12 for Basic Life Insurance benefits plus interest.77 However, MetLife
denied the claim for Optional Life Insurance, explaining as follows in its denial letter:
According to our records, Jason Guidry elected Optional Life
Insurance coverage to be effective January 1, 2024. The
Death Certificate issued by the State of Louisiana indicates
that 	Jason 	Guidry 	passed 	away 	on 	January 	9, 	2024.
According to the records of [Waste Management], Jason
Guidry had a job status of Leave of Absence, with a date last
worked of December 12, 2023, and did not return to work prior
to passing away. 78
For this reason, MetLife concluded Jason Guidry was not “actively at work” on January 1,
2024, as required under the Plan for the optional coverage to take effect.79
Plaintiff argues that Jason Guidry should be considered an “active employee” as
of January 1, 2024, because he “was not accorded all of his vacation time and Family
Medical Leave Extended Time that allowed him to be classified, according to the Plan
Administrators, as ‘actively at work.’” 80 Plaintiff cites no evidence to support this assertion.
There is also no evidence supporting Plaintiff’s theory that MetLife (or any of the
75 Rec. Doc. 47-1, pp. 12–15.
76 Id. at pp. 34–35.
77 Id. at pp. 72–73. Plaintiff acknowledges receipt of this payment in her Complaint. See Rec Doc. 1, ¶
VIII(V).
78 Id. at pp. 50–51. See also Rec. Doc. 47-2, p. 8 (reflecting Jason Guidry’s last date of work was December
12, 2023).
79 Id.
80 Rec. Doc. 64, pp. 1–2.
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Defendants) 	“manipulated 	the 	process 	to 	place 	him 	outside 	of 	his 	employment
prematurely” in an intentional effort to eliminate the Optional Life Insurance coverage.81
After reviewing the record, the Court finds that MetLife’s denial of Plaintiff’s claim
for Optional Life Insurance coverage was not an abuse of discretion. MetLife reasonably
denied coverage on the basis that Jason Guidry was not “actively at work” on the date
the Optional Life Insurance coverage took effect, and Plaintiff has pointed to no evidence
showing otherwise. Accordingly, MetLife’s Motion for Judgment on the Administrative
Record will be granted.
4. 	Liability of LINA
In February of 2019, LINA entered into an Administrative Services Agreement with
Waste Management whereby LINA agreed to provide administrative service relating to
Wate Management’s leave policies. 82 In 2021, LINA entered into an Amendment of the
Administrative Services Agreement whereby LINA agreed to provide administrative
services regarding a self-funded salary continuance plan providing short-term disability
benefits. 83
On December 22, 2023, LINA sent Jason Guidry a letter approving his claim for
short-term disability benefits. 84 The letter indicates a date of disability of December 12,
2023, and notes that benefits had been approved through January 14, 2024. 85 On
January 9, 2024, LINA approved Jason Guidry’s request for “Administrative Leave 6” and
FMLA leave from the date of disability through January 14, 2024. 86
81 Id. at p. 2.
82 Rec. Doc. 35-3.
83 Rec. Doc. 35-4.
84 Rec. Doc. 35-2, pp. 3–4.
85 Id.
86 Id. at pp. 146–149.
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Plaintiff argues it is “suspicious” that LINA did not give notice as to the status of
Jason Guidry’s leave request until the date of his death. 87 However, Plaintiff cites no
record evidence supporting her allegations of fault against LINA. LINA approved the
requests for leave and short-term disability coverage and was not involved in the denial
of Optional Life Insurance. Further, there is no evidence supporting the argument that
LINA (or any of the Defendants) convinced Jason Guidry or Plaintiff “that they would be
better off” if Jason Guidry sought leave status and short-term disability, thereby depriving
them of Optional Life Insurance coverage. Accordingly, Plaintiff’s claims against LINA will
be dismissed.
III. 	CONCLUSION
For the foregoing reasons,
Life Insurance Company of North America’s Motion for Partial Summary Judgment
on the Issue of ERISA Preemption88 is GRANTED;
Metropolitan 	Life 	Insurance 	Company’s 	and 	Waste 	Management 	National
Services, Inc.’s Motion for Partial Summary Judgment89 is GRANTED;
Waste Management’s Motion for Judgment on the Administrative Record 90 is
GRANTED;
MetLife’s Motion for Judgment on the Administrative Record 91 is GRANTED;
LINA’s Response Brief on the Merits, 92 which the Court construes as a Motion for
Judgment on the Administrative Record, is GRANTED;
87 Rec. Doc. 64, p. 7.
88 Rec. Doc. 40.
89 Rec. Doc. 44.
90 Rec. Doc. 65.
91 Rec. Doc. 66.
92 Rec. Doc. 67.
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Plaintiff’s Opening Brief on the Merits,93 which the Court construes as a Motion for
Judgment on the Administrative Record, is DENIED.
The Motions to Dismiss filed by MetLife 94 and Waste Management 95 will be
terminated as moot.
Plaintiff’s action is hereby dismissed with prejudice. Judgment shall be entered
accordingly.
IT IS SO ORDERED.
Baton Rouge, Louisiana, this ___ day of _______________, 2026.
________________________________
SHELLY D. DICK
CHIEF DISTRICT JUDGE
MIDDLE DISTRICT OF LOUISIANA
93 Rec. Doc. 64.
94 Rec. Doc. 17.
95 Rec. Doc. 18.
7th January
S
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