Barnett v. International Business MacHines Corp.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that “a security interest or lien in the proceeds of a pending lawsuit generally does not become choate until a settlement or judgment is obtained because the property to which the lien is attached is not ‘in existence’ until that time”
• agreeing with district court that cause of action accrued in 1986 when facts demonstrated futility since 1986
• in ERISA action by beneficiary, federal court looks to forum state's borrowing statute to determine which state's limitations period applies
• “Th[e] exhaustion requirement is a jurisdictional prerequisite to a suit for benefits.”
• “[I]f an informal or unsubstantiated denial of a “claim” that was never filed or formally presented is reviewable in the federal courts, then, in such situations, the courts and not ERISA trustees will be primarily responsible for deciding claims for benefits.”
• “Usually, the futility exception is applied in a context in which there has been, in some form, an unambiguous application for benefits and a formal or informal administrative decision denying benefits and it is clear that seeking further administrative review of the decision would be futile.”

Source: CourtListener parenthetical corpus (CC0).