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DISABILITY BENEFITS

Zaeske v. Liberty Life Assurance Company of Boston

The Eighth Circuit Court of Appeals reverses a district court decision and finds that the defendant insurance company did not abuse its discretion in denying long-term disability (LTD) benefits under the welfare benefit plan of the plaintiff's employer. The plaintiff is an employee covered under a welfare benefit plan that provides LTD benefits. The plan is governed by the Employee Retirement Income Security Act of 1974 (ERISA). The defendant is the insurance company that insures and administers the LTD benefits under the plan. The plaintiff stopped working due to chronic back pain and applied for LTD benefits under the plan. In evaluating the claim, the defendant obtained medical records from the plaintiff's treating physicians and then submitted those records to an independent consulting physician. The independent consulting physician determined that the plaintiff's current work capacity should be limited to sedentary work rather than the light work currently required by his job but that the defendant should continue to obtain updated medical records for ongoing review of his condition. The defendant initially approved the plaintiff's claim, subject to periodic evaluation of his disability. After receiving updated medical records at a later date, the defendant terminated the plaintiff's LTD benefits, finding that he could work on a full-time basis despite his medical conditions. The plaintiff appealed the decision. The appeal was denied, and the plaintiff subsequently filed suit under ERISA. The district court held that the defendants decision to terminate the plaintiff's LTD benefits was not supported by substantial evidence and was therefore an abuse of discretion. The district court ordered the defendant to pay the plaintiff for past-due benefits and attorney fees. The defendant appealed to this court, which reviews the decision de novo. A decision by a plan administrator is not an abuse of discretion if it is reasonable, which means that it is supported by substantial evidence. The district court determined that the defendant's decision was unreasonable because it relied on opinions of independent consulting physicians that the court found to be unreliable. This court disagrees with that determination and finds that the opinions of the independent consulting physicians were sufficiently reliable to provide a reasonable basis to deny the plaintiff's claim. Therefore, it was not an abuse of discretion for the defendant to rely on those opinions. Accordingly, the court reverses the district court decision and finds that the defendant's decision was not an abuse of discretion. No. 17-2496 (8th Cir. August 23, 2018).

BENEFIT CALCULATION

Fowler et al. v. Guerin

The Ninth Circuit Court of Appeals reverses a district court denial of a stipulated motion to certify a class and dismissal of the action as prudentially unripe. The case related to an action brought by public school teachers seeking a return of interest allegedly skimmed from their retirement accounts. The plaintiffs are a class of public school teachers...

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