Andre LeGras sought continued disability benefits and pursued an administrative appeal after receiving a denial. The appeal deadline fell on a weekend, and Aetna treated the appeal as untimely, asserting that the missed deadline barred judicial review of the claim.
Kantor & Kantor challenged Aetna’s rigid deadline interpretation and argued that ERISA exhaustion requirements are governed by federal common law, not hyper-technical timing rules designed to shut claimants out of court.
The Ninth Circuit held that when an appeal deadline falls on a weekend, the deadline extends to the next business day. The decision reversed dismissal of the claim and prevented insurers from using technical deadline traps to avoid judicial review of benefit denials.
