ERISA-Second Circuit Rules That Plaintiff Is Not Entitled To Reinstatement Of Long-Term Disability Benefits

In Baird v. The Prudential Insurance Company of America, No. 10-4179-cv (2nd Cir. 2012) (Summary Order), the plaintiff, Mona Baird (“Baird”), was appealing from a grant of summary judgment against her by the district court, which denied her claim under ERISA for reinstatement of long-term disability (“LTD”) benefits for her bilateral Carpal Tunnel Syndrome. The defendant, Prudential Insurance Company of America (“Prudential”), was the claims administrator of the plan which had paid the LTD benefits. Prudential had decided to terminate the LTD benefits, on the grounds that Baird was no longer “disabled” within the meaning of the plan.

In the appeal, Baird had argued that the district court’s grant of summary judgment was erroneous, because Prudential’s conclusion that she was no longer “disabled” was not supported by substantial evidence, and was the result of Prudential’s failure to consider the duties of her regular occupation in a meaningful way. However, the Second Circuit Court of Appeals (the “Court”) said that Baird’s arguments amount to nothing more than a disagreement about how Prudential should have evaluated the medical evidence. Where, as here, the terms of an employee benefit plan grants the claims administrator discretion to determine eligibility for benefits, such arguments do not provide a basis for overturning a benefit determination. Rather, the Court said that it will not disturb the administrator’s ultimate conclusion, unless it was arbitrary and capricious (which it was not here). As such, the Court affirmed the district court’s grant of summary judgment against Baird.

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