Judge: Mailbox Presumption Not Established In ERISA Suit Over LTD Benefits

( August 6, 2026, 11:20 AM EDT) -- CHICAGO — Granting judgment against a long-term disability (LTD) claimant on the grounds that he failed to exhaust his administrative remedies, a Chicago federal judge ruled that “a federal common law presumption that mail properly sent is received” isn’t established because “there is insufficient evidence that the purported appeal letters were properly directed and mailed” — and “even if the mailbox presumption might otherwise apply, it is defeated both by Plaintiff’s error in addressing the January 2022 letter and Defendant’s robust evidence of nonreceipt.”...