In Van Steen v. Life Insurance Company N.A., No. 16-1405 (10th Cir. 2018), the appeal arose out of the termination by Life Insurance Company of North America (“LINA”) of Carl Van Steen’s long-term disability benefits under Lockheed Martin’s benefit plan, which is subject to ERISA. LINA appeals the district court’s finding that its decision to terminate Mr. Van Steen’s benefits was arbitrary and capricious, so that the district court overturned LINA’s decision. Upon reviewing the case, the Tenth Circuit Court of Appeals (the “Court”) affirmed the district court’s ruling.
In this case, Van Steen was employed as a Systems Integration Business Analyst at Lockheed Martin Corporation. As such, he was a participant in the Lockheed Martin Group Benefits Plan (the “Plan”), which is administered and insured by LINA. In October 2011, Van Steen was physically assaulted during an altercation while walking his dog. The assault resulted in a mild traumatic brain injury (“mTBI”) that impacted Mr. Van Steen’s cognitive abilities. This cognitive dysfunction ultimately prevented him from functioning in his job.
Van Steen applied for and an initially began to receive long-term disability benefits from the Plan. However, LINA later decided to terminate the benefits, on the grounds that the medical documentation does not show that Van Steen’s condition precludes him from resuming his work. Van Steen then filed suit, challenging the termination of his benefits. The case wound up before the Court.