ERISA-Fourth Circuit Upholds The Administrator’s Decision That The Plaintiff Is Not Disabled Within The Meaning Of The Plan

In Mullins v. AT &T Corporation, Nos. 04-2135, 04-2136, 07-1717, 10-2010 (4th Cir. 2011 ) (Unpublished Opinion), the plaintiff, Margaret Mullins (“Mullins”), had appealed the district court’s grant of summary judgment against her, on her claim for disability benefits. The benefits would be payable under a long-term disability plan (the “Plan”), which was self-funded by Mullins’ employer, AT&T Corporation (“AT&T”), administered by Connecticut General Life Insurance Company (“CGLIC”), and governed by ERISA.

Under the Plan, an employee is generally considered disabled if, in the sole opinion of CGLIC, the employee is determined to be incapable of performing the requirements of any job for any employer (including non-AT&T employment), for which the individual is qualified or may reasonably become qualified by training, education or experience, other than a job that pays less than 50 percent of the employee’s annual base pay. In April 1998, Mullins was diagnosed with bilateral carpal tunnel syndrome (“CTS”), which caused her to experience sensitivity and pain in her hands. Mullins also had diabetes, which was thought to aggravate her CTS condition. In September 1999, Mullins applied for disability benefits under the Plan, claiming that the pain and weakness in her hands rendered her “incapable of performing the requirements of any job for any employer” under the terms of the Plan. CGLIC denied the application, and Mullins filed this suit under ERISA. The issue for the Court: was Mullins disabled within the meaning of the Plan?

In analyzing the case, the Court stated that, since the Plan confers discretion on the administrator to interpret its provisions and issue a determination on a claim for benefits, the Court must review CGLIC’s denial of Mullins’ claim for benefits under the abuse-of-discretion standard. As such, CGLIC’s denial will be upheld if it is “reasonable”, that is, if it is the result of a deliberate, principled reasoning process and it is supported by substantial evidence. The Court concluded that CGLIC’s decision was reasonable. Mullins had been seen by two surgeons and a neurologist for the pain and sensitivity in her hands. The medical opinions of these physicians conflicted, both as to her specific diagnosis as well as to her functional capacity to perform work. It was CGLIC’s responsibility, and within its discretion, to resolve this conflict. CGLIC had reasonably considered and relied upon the opinions of two of Mullins’ treating physicians, as well as the results of a functional capacity examination, which indicated that Mullins was capable of performing sedentary work within her limitations. CGLIC further determined that there were actual jobs available in the relevant market which Mullins could perform within her limitations and earn at least the 50% minimum required by the Plan. Based on the foregoing, CGLIC concluded that Mullins had failed to prove that she was “incapable of performing the requirements of any job for any employer” for which she was or could become reasonably qualified, and therefore Mullins was not disabled within the meaning of the Plan. The Court concluded that CGLIC’s determination was clearly supported by substantial evidence in the administrative record, and it affirmed the district court’s summary judgment against Mullins.

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