ERISA-Seventh Circuit Holds That Letters Denying A Claim For Disability Benefits Without Refuting Contrary Evidence Were Not Sufficient To Support Summary Judgment

In Love v. National City Corporation, No. 08-1722 (7th Cir. 2009), the plaintiff, Nancy Love, had worked for National City Corporation for twenty years before leaving due to health problems. After her physician diagnosed her with multiple sclerosis, Love applied for and received short term disability benefits–and subsequently long-term disability benefits–through National City’s Welfare Benefits Plan (“the Plan”). However, three years after Love began receiving disability benefits, the Plan administrator terminated her benefits, by a letter stating that she no longer fit the Plan’s definition of “disabled.” To be “disabled” under this definition, an employee can no longer perform any job. Love appealed the benefits-termination decision and the Plan denied her appeal, again by letter. Love then sued the Plan under ERISA, alleging that her disability benefits were terminated without sufficient explanation or medical support. The district court granted summary judgment for the Plan. However, the Seventh Circuit found that the Plan did not adequately explain why it concluded Love was no longer disabled. Therefore, it reversed the judgment of the district court, with instructions to remand to the Plan administrator for further proceedings.

As to Love’s ERISA claim, the Court noted that ERISA requires a plan administrator to communicate specific reasons for a denial of benefits to the claimant, and to address any reliable evidence of eligibility for those benefits put forward by the claimant. The Plan had received reports and records which contained evaluations and conclusions of Love’s own treating physicians, and which indicated that Love could not perform any job and was “disabled” within the Plan’s definition. Here, neither the initial benefits termination letter from the Plan administrator, nor the subsequent letter denying Love’s appeal, sufficiently explained the denial. Both letters asserted that all relevant medical evidence had been considered in determining that Love was not disabled, but neither letter addressed the contrary evaluations and conclusions of Love’s own physicians or explained why the reviewer discredited those evaluations and conclusions.

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