The administrator of a dental benefits plan argued that it had no legal relationship with an employee. The court refused to dismiss the action at this stage, while finding that the claim appeared tenuous.

The defendant in this dispute, The Canada Life Assurance Company (Canada Life), administers the dental benefits plan offered by the employer of the plaintiff, Sonia Delamarre.

The plaintiff is suing Canada Life for $4,112. She maintains that the plan’s coverage included orthodontic expenses for her dependent children, who are full-time students. She incurred expenses of approximately $8,000 before her claim was denied.

According to the plaintiff, the insurer confirmed several times, both in her online account and through its app, that the claim had been “pre-approved.” She alleges that the defendant wrongly led her to believe that the expenses were eligible for coverage.

No legal relationship

According to the insurance company, it is acting in this case not as an insurer, but solely as the administrator of the plan established by the plaintiff’s employer, Canada Post Corporation. The defendant maintains that no legal relationship exists between it and the plaintiff. Consequently, financial responsibility for any claim would rest with the employer.

At the hearing held in Quebec City on October 8, Ms. Delamarre acknowledged that no insurance contract directly binds her to the defendant and that her claim is not based on such a contract.

The court must determine whether the defendant has convincingly demonstrated the absence of a legal relationship between itself and the plaintiff, such that no legal action could be brought against it.

The court’s reasoning

Justice Manon Gaudreault, of the Small Claims Division of the Court of Québec, rendered her decision on October 23, 2026. Published only in French, it concerns only Canada Life’s application to dismiss the action. The judgment does not address the merits of the claim, which will be the subject of a future judgment once the evidence has been presented.

The court first recalls a principle set out in a legal treatise on group insurance published in 2006. In a self-insured plan managed by an insurer acting as administrator, “if a claim is denied, the plan member has recourse only against their employer, as no legal relationship exists between the member and the insurer.”

If the claim were based solely on the refusal to pay benefits under the plan, the action would have been brought against the wrong party. The claim could then arise from the application of the collective agreement and fall within the jurisdiction of another tribunal.

In her submissions, the plaintiff points out that the plan administrator erroneously led her to believe, at different times and through different platforms, that the expenses were eligible for coverage when they were not. Ms. Delamarre alleges that this fault on Canada Life’s part caused her damages.

In this regard, Justice Gaudreault notes that the plaintiff appears to be confusing contractual obligations between the insured and the insurer with extracontractual obligations. Although the merits of her allegations have not been established and her action appears tenuous, the court finds that the case must be allowed to proceed and denies Canada Life’s application for dismissal.

When presenting her evidence, Ms. Delamarre will have to establish precisely and convincingly the fault committed by the defendant, the damages she suffered and the causal link between the two. “It will also be important to make the necessary distinctions between the employer’s liability and that of the plan administrator,” the court writes.