ERISA-Fourth Circuit Overturns District Court’s Denial Of Claim For Short Term Disability Benefits, And Sends The Case Back To Plan Administrator For Further Review

In Harrison v. Wells Fargo Bank, N.A., No. 13-2379 (4th Cir. 2014), plaintiff Nancy Harrison brought suit against her employer Wells Fargo, arguing that the company improperly terminated her short-term disability benefits while she was undergoing a series of treatments for thyroid disease. The district court upheld Wells Fargo’s decision, finding that it, as the plan administrator, did not abuse its discretion in denying Harrison’s claim.

However, the Eleventh Circuit Court of Appeals (the “Court”) analyzed the case and said that Wells Fargo failed to consider readily available material evidence of which it was put on notice (i.e., evidence that Harrision was seeking treatment for mental health conditions and certain properly signed release forms from Harrison evidencing the disability), and to inform Harrison in clear terms that her own doctor’s records could establish her claim. Therefore, the Wells Fargo review process failed to conform to the directives of ERISA (requiring, among other things, a full and fair review and a deliberate, principled reasoning process which supports its decision with substantial evidence) and the Plan’s own terms. As such, the Court reversed the district court’s decision, and remanded the case back to the district court, with directions to return the case to Wells Fargo, as plan administrator, for a full and fair review of Harrison’s claims.

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