ERISA-District Of Columbia Court Of Appeals Upholds District Court’s Grant Of Disability Benefits

In Marcin v. Reliance Standard Life Insurance Company, No. 16-7125 (District of Columbia Court of Appeals 2017), the District of Columbia Court of Appeals (the “Court”) was faced with an appeal concerning Jill Marcin’s recovery of long-term disability benefits under an ERISA-governed plan.

In 2008, Ms. Marcin filed for disability benefits under the Mitre Long Term Disability Plan, Group Policy Number 111701 (the “Plan” or “Policy”), citing numerous ailments that affected her cognitive abilities and motor functioning. Reliance Standard Life Insurance Company (“Reliance”), the Plan administrator, denied Ms. Marcin’s request for benefits, explaining that she did not meet the definition of “Total Disability.” In particular, Reliance concluded that Ms. Marcin was capable of performing all material duties of her employment on a full-time basis. Following an unsuccessful administrative appeal, Ms. Marcin filed suit against Reliance and the Plan in District Court in 2010.  The District Court remanded the case to Reliance, requesting additional explanation as to how the record supported Reliance’s conclusion that Ms. Marcin was not disabled.

In early 2013, Reliance again denied Ms. Marcin’s claim for disability benefits. Ms. Marcin filed a second lawsuit in District Court, which serves as the basis for this appeal. Following an additional remand, the District Court entered judgment in favor of Ms. Marcin on October 14, 2015. Specifically, the District Court found that there was not substantial evidence in the record to support Reliance’s denial of disability benefits, though it cautioned that it was not making a finding that Ms. Marcin was Totally Disabled. In subsequent orders, the District Court determined that Ms. Marcin was entitled to disability benefits in the amount of $2,409.74 per month, along with post-judgment interest at the rate of 0.27 percent per annum from October 14, 2015, and attorney’s fees in the amount of $72,240.

Reliance timely appealed, arguing that the District Court erred by awarding Ms. Marcin disability benefits and miscalculating the amount of benefits owed. In analyzing the case, the Court said that Reliance’s strongest argument on appeal is that benefits under the Plan cannot be awarded without a factual finding of Total Disability. Given that the District Court explicitly disavowed making this determination, Reliance contends that an award of benefits was legally precluded. However, said the Court, while we agree with Reliance that a finding of Total Disability was a prerequisite to the receipt of benefits, we are mindful of our de novo standard review for summary judgment. Pursuant to this standard, continued the Court, we may affirm the District Court on any ground, and elect to do so on the basis that Ms. Marcin proved Partial Disability. The conflict of interest factor in the standard of review, combined with Ms. Marcin’s medical record, lack of full-time work, and release to return to work only “as tolerated” convince us that Ms. Marcin established Partial Disability as required by the Policy. Reliance has not satisfactorily supported its conclusion that Ms. Marcin was ever capable of full-time work after November 2007. According to the express terms of the Plan, Partial Disability is equivalent to Total Disability, and the Court found that Ms. Marcin was Totally Disabled within the relevant period. As such, the Court affirmed the grant of the disability benefit.  The Court also affirmed the District Court’s calculation of disability benefits owed to Ms. Marcin.

 

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