In Vangas v. Montefiore Medical Center, 2016 WL 2909354 (2d Cir. May 19, 2016), the Second Circuit affirmed the district court’s holding that an employer is not liable for failing to provide a COBRA notice to a terminated employee under ERISA § 502(c) where the employer followed reasonable procedures to ensure that notices were properly mailed.  The Court rejected the terminated employee’s argument that the notice was deficient because it was incorrectly addressed to “Cornwallonhuds, New York,” rather than to her actual address, “Cornwall-on-Hudson, New York.” 

In so ruling, it noted that the mailing contained the proper zip code and the terminated employee’s admission to “receiving eighteen other pieces of incorrectly addressed mail, including mail without the zip code” at that address.