ERISA-Sixth Circuit Rules That Plan Was Arbitrary And Capricious In Denying Plaintiff His LTD Benefits, And Then Awarded The LTD Benefits To The Plaintiff

In Shaw v. AT&T Umbrella Benefit Plan No. 1, No. 14-2224 (6th Cir. 2015), plaintiff Raymond Shaw sued defendant AT&T Umbrella Benefit Plan (“the Plan”), alleging that the Plan denied his claim for long-term disability (“LTD”) benefits, stemming from chronic back pain, in violation of ERISA. The district court granted summary judgment to the Plan, finding that the Plan had properly denied Shaw benefits.

In analyzing the case, the Sixth Circuit Court of Appeals (the “Court”) found that the Plan acted arbitrarily and capriciously in denying Shaw LTD benefits. Although the Plan determined that there was not objective medical documentation of Shaw’s inability to perform any occupation, it ignored favorable evidence submitted by his treating physicians, selectively reviewed the evidence it did consider from the treating physicians, failed to conduct its own physical examination, and heavily relied on non-treating physicians.

Further, since the Court found that Shaw has demonstrated that he was denied benefits to which he was clearly entitled, the Court remanded the case to the district court and directed it to enter an order awarding Shaw his LTD benefits.

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