Appeals Court Reverses, Orders Retroactive Disability Benefits
Wednesday, January 26th, 2011
A Federal Appeals Court, for the Third Circuit, has reversed a lower court ruling and awarded the payment of long term disability insurance benefits to a claimant, a commercial pilot, whose benefits had been terminated. The claimant, who suffered from severe mental health problems, finally has success to an odyssey that began in May 2003 when his benefits were originally terminated. While the claim was later re-opened, it was again terminated in 2006.
The Appeals Court covered a number of important areas in the ERISA disability arena, in arriving at its determination. It addressed the issue of a conflict of interest, in light of Met Life v. Glenn, and a host of procedural factors which impacted the Court’s decision. These included a reversal of the claim position, despite no meaningful change in the claimant’s condition, a reliance upon non-existent plan requirements, imposing upon the claimant requirements which were not part of his plan obligations, a failure to properly advise the claimant how to perfect his claim, a failure to examine all relevant medical diagnoses, and a failure to properly consider the job requirements in reaching a claim determination. As the Court noted “we find this analysis persuasive because it is essential that any rational decision to terminate disability benefits under an own-occupation plan consider whether the claimant can actually perform the specific job requirements of a position.”
This case should prove to be helpful to the claimant community, in that the Third Circuit Court of Appeals has addressed a number of commonly seen claim handling “techniques” from all the major long term disability insurance companies. This Court adjudicated the claim based upon the totality of factors, determining the “lawfulness” of the claim decision, and finding that the decision was arbitrary and capricious.