In Owings v. United of Omaha Life Insurance Company, No. 16-3128 (10th Cir. 2017), plaintiff Greggory Owings (“Owings”) sustained a disabling injury on the job and was afforded long-term disability benefits by defendant United of Omaha Life Insurance Company (“United”), under the terms of a group insurance policy issued by United to Owings’ employer. Owings disagreed with, and attempted without success to administratively challenge, the amount of his disability benefits. He then filed suit against United in Kansas state court, but United removed the action to federal district court, asserting that the federal courts had original jurisdiction over the action because the policy was governed by ERISA. The district court ultimately granted summary judgment in favor of United on the amount of the disability benefits. Owings then appealed.
Upon reviewing the case, the Tenth Circuit Court of Appeals (the “Court”) concluded that United was arbitrary and capricious in determining the date that Owings became disabled (since United did not correctly interpret the plan language, in particular the definition of “Disability”) and, in turn, in calculating the amount of his disability benefits. Consequently, the Court reversed the district court’s grant of summary judgment in favor of United, and remand the case back to the district court, with directions to enter summary judgment in favor of Owings.