ERISA-Sixth Circuit Rules Upholds The Plan Administrator’s Determination To Deny Long-Term Disability Benefits

In McClain v. Eaton Corporation Disability Plan, No. 13-5395 (6th Cir. 2014), the relevant long-term disability plan provided that the plaintiff was disabled if she was “totally and continuously unable to engage in any occupation or perform any work for compensation or profit.” (Emphasis added.) The defendant plan administrator denied the plaintiff’s claim for disability benefits, because her treating physician opined she could work part-time, and a market study identified various part-time positions in the area for which she was qualified. The plan administrator thus took the position that the plaintiff was not totally disabled from doing any work because she could do some work.

In analyzing this case, the Sixth Circuit Court of Appeals (the “Court”) stated that its review is limited to determining whether this determination by the plan administrator-which had discretionary authority over the plan- is arbitrary and capricious. The district court found that it was not. The Court agreed, concluding that, based on the whole administrative record which included the records of plaintiff’s physicians and two independent doctors who reviewed the case, the plan administrator’s decision to deny to disability benefits was rational and based on a reasonable reading of the plan’s provisions.

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