In Dragus v. Reliance Standard Life Insurance Co., No. 17-1752 (7th Cir. 2018), Plaintiff-appellant, John Dragus, brought suit against defendant-appellee, Reliance Standard Life Insurance Company (“Reliance”), under ERISA for denial of long-term disability (“LTD”) benefits. After the district court denied Dragus’ request for discovery outside the claim file record, both parties moved for summary judgment. Before the court ruled, Dragus filed a motion to supplement the claim record with a fully favorable Social Security Disability Insurance (“SSDI”) decision. The district court denied the motion to supplement and granted summary judgment in favor of Reliance. Dragus then appealed.
Upon reviewing the case, the Seventh Circuit Court of Appeals (the “Court”) affirmed the district court’s decisions. The Court found that the applicable insurance policy grants Reliance a discretionary review of claims, and with any conflict of interest appropriately eliminated by Reliance, no contention of bad faith or fraud, and a well-reasoned decision supported by the evidence, Reliance’s decision to deny the LTD benefits was not arbitrary or capricious.