Background
Debbie McCravy had life and AD&D coverage through her employer’s MetLife plan and elected coverage for her daughter as an eligible dependent. Under the summary plan description, a child stopped being eligible at 19, or at 24 if a full-time student. MetLife kept accepting premiums for the daughter’s coverage from before her nineteenth birthday until she was murdered in 2007 at age 25. It then denied the claim because she was too old to be covered and tried to refund the premiums. McCravy refused the check and sued, alleging that MetLife had represented that her daughter was covered and that, believing so, the daughter did not buy other insurance.
The district court held that her state-law claims were preempted and that ERISA limited her to a refund. It entered judgment for $311.09 in premiums, while noting that this rule left plan providers with little reason not to collect premiums for coverage that did not exist.
What the court held
The Fourth Circuit first affirmed, but the Supreme Court decided CIGNA Corp. v. Amara the same day, and the panel reheard the case. Under Amara, the “appropriate equitable relief” that ERISA § 502(a)(3) allows against a fiduciary includes remedies traditionally available in equity, including surcharge (monetary make-whole relief against a trustee) and equitable estoppel (holding a party to what it represented). McCravy sought estoppel to stop MetLife from relying on the fact that her daughter’s coverage was never converted to an individual policy within 31 days of her turning 19. So McCravy’s recovery was not limited to a refund as a matter of law. The court reversed, vacated the refund judgment and sent the case back. It left for the district court whether MetLife actually breached a fiduciary duty and whether either remedy was appropriate on the facts. It also noted that only the summary plan description, not the plan itself, was in the record, and that the case would turn on the actual plan documents.
The court also explained why the rule matters: if the worst outcome for a fiduciary that wrongly took premiums were returning them, it would keep the premiums from everyone who never filed a claim.
Why it matters
Paycheck deductions or premium payments for coverage the insurer later says never took effect are a recurring problem in employer group life claims. McCravy shows that a beneficiary in that position may have an equitable claim worth more than the refund. It is a Fourth Circuit decision; other circuits apply Amara in their own ways, and the facts and plan documents still decide each case. A related decision is Silva v. MetLife.
Read the opinion
McCravy v. Metropolitan Life Ins. Co., 690 F.3d 176 (4th Cir. 2012) (CourtListener). Opinion read in full November 2, 2026.
Not legal advice. This page summarizes general rules and the specific statutes cited. Your policy's wording, the state whose law applies, and whether the coverage came through an employer can all change the result. See the disclaimer and editorial policy.