David C. Pellegrin
U.S. Court of Appeals for the Fifth Circuit Rules in Favor of Life Insurance Beneficiary
In a recent decision, Edwards v. Guardian Life Insurance Company of America, No. 24-60381, 2025 WL 1718263 (5th Cir. June 20, 2025), the U.S. Court of Appeals for the Fifth Circuit issued a rare ruling that favors employees and beneficiaries in group life insurance disputes. In this case, the court made clear that an insurance company cannot continue collecting premiums for years and later deny coverage based on a technical eligibility argument.
The Plaintiff in the case was a beneficiary of a life insurance policy issued by Guardian Life Insurance Company of America. Guardian continued accepting premium payments for more than two years.
After the insured passed away, Guardian denied the claim for life insurance benefits. The company took the position that the policy was not valid at the time of death because it supposedly should have been terminated earlier. The beneficiary challenged that denial in federal court.
The Fifth Circuit rejected Guardian’s argument. The court held that even if the insurer technically had the right to cancel the policy, it gave up that right by continuing to accept premiums long after the alleged cancellation condition arose. In plain terms, the court said that an insurance company cannot keep taking money while silently reserving the option to deny coverage later. That conduct amounted to a waiver of the cancellation provision. The court also confirmed that the policy was governed by ERISA because the workers involved were properly classified as employees, not independent contractors.
This decision is significant for anyone dealing with denied life insurance or disability claims under employer sponsored plans. Insurers frequently rely on technical defenses related to eligibility, enrollment, or participation. Edwards reinforces that those defenses may fail when the insurer’s own conduct contradicts them, especially when premiums were knowingly accepted.
If your life insurance or disability claim has been denied under an ERISA plan, particularly where premiums were paid and accepted, this case may be directly relevant. An experienced ERISA attorney can evaluate whether the insurer’s conduct amounts to waiver or another violation of federal law.