ERISA-Fourth Circuit Upholds District Court’s Decision That Plaintiff Is Entitled To Disability Benefits

In Solomon v. Bert Bell/Pete Rozelle NFL Player Retirement Plan, No. 16-1730 (4th Cir. 2017), the appeal raises the issue of whether the plan administrator for the defendants, the Bert Bell/Pete Rozelle NFL Player Retirement Plan and the NFL Player Supplemental Disability Plan (collectively, the “Plan”), abused its discretion in denying a certain type of disability benefits to the plaintiff, Jesse Solomon (“Solomon”).  After the plan administrator determined that Solomon ‘s disability-onset date rendered him ineligible for the benefits he sought, Solomon brought suit under § 502(a)(1)(B) of ERISA.

The district court concluded that Solomon was entitled to the benefits he claimed and ordered the Plan to provide them.  Because the Fourth Circuit Court of Appeals (the “Court”) found that the plan administrator failed to follow a reasoned process or explain the basis of its determination to deny the benefits—neither addressing nor even acknowledging new and uncontradicted evidence supporting Solomon’s  application, including that of the Plan’s own expert—the Court affirmed the district court’s decision.

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