Syed v. Hercules, Inc., 214 F.3d 155 (3^rd Cir. 2000)-Syed filed suit against his former employer after it discontinued his long-term disability benefits after two years.  Hercules discontinued the benefits based on a doctor's opinion that he could do "sedentary to light" work (and therefore no longer met the definition of "total disability").  Syed made four arguments on appeal.  This court affirmed the denial of all arguments on appeal.  First, he contended that the district court used the wrong statute of limitations to deny his claim.  This court affirmed the district court's choice of Delaware's one-year statutory limit for wage and benefit disputes instead of Delaware’s three-year limit for general contract disputes.  The test is whether, as a whole, the coverage of the statute is more analogous to the ERISA claim. 

Second, Syed requested the imposition of sanctions under 29 U.S.C. § 1132(c) against Hercules for failure to provide him with the plan document pursuant to a written request.  This court found this argument lacking, because although Hercules provided him with a plan summary instead of the plan itself, the two were "identical in all respects material to this dispute."

Third, Syed argued that Hercules violated 29 U.S.C. § 1133 both by failing to provide specific reasons for the denial of his claim and by neglecting to name any additional material or information that would have helped him perfect his claim.  This court found that Hercules' letter clearly contained all the required elements of notice, namely:  "(1) The specific reason or reasons for the denial; (2) Specific reference to pertinent plan provisions on which the denial is based; (3) A description of any additional material or information necessary for the claimant to perfect the claim and an explanation of why such material or information is necessary; and (4) Appropriate information as to the steps to be taken if the participant or beneficiary wishes to submit his or her claim for review."

Finally, Syed asserted that the District Court should have exercised plenary review over the Claims Fiduciary's decision to deny his benefits, rather than reviewing for an abuse of discretion, as the Plan did not grant discretion to the Claims Fiduciary to make a disability determination.  This court found no need to address this claim, since the statute of limitations had run.