Edwards v. Briggs & Stratton Retirement Plan

Dist. Ct. did not err in granting defendant-plan's motion for summary judgment in ERISA action challenging defendant's denial of plaintiff's application for disability benefits. Record showed that plaintiff failed to exhaust her administrative remedies by filing internal appeal of denial that was 11 days late. Moreover, plaintiff failed to show that 180-day period provided by defendant for filing internal appeal was too short of time period so as to deprive her of meaningful access to appeal procedures or that any administrative appeal would have been futile. Ct. also rejected defendant's argument that her untimely internal appeal should have been excused because she substantially complied with defendant's administrative review procedures.