Equitable Tolling and ERISA

In Turbville v. Metro. Life Ins. Co., 2012 U.S. Dist. LEXIS 153969 (N.D. Alabama, 10/26/2012), the District Court held: It is ‘simply illogical’ not to toll the limitations period when requiring administrative exhaustion, for otherwise, a cause of action could accrue and be immediately subject to dismissal.” Jeffries, 169 F. Supp. 2d at 1383 (quoting Mitchell, 1997 U.S. Dist. LEXIS 7323, at *5). Therefore, the statute of limitations was tolled while plaintiff exhausted her administrative remedies.”


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