A district court in New York recently overturned a disability benefit termination decision by MetLife, citing a number of reasons and highlighting several issues that frequently arise in disability claims. In Solomon v. MetLife, 2009 U.S.Dist.LEXIS 51507 (S.D.N.Y. June 18), Judge Robert W. Sweet from the Southern District of New York, presented a thoughtful analysis worthy of discussion.
The 1st U.S. Circuit Court of Appeals has issued a major ruling on how courts are to assess employee benefit claim decisions made within the context of ERISA. In Denmark v. Liberty Life Assur.Co. of Boston, 2009 U.S.App.LEXIS 9825 (May 6), the court revisited an earlier ruling in a disability benefits claim involving fibromyalgia (Denmark […]
The impact of a recent Supreme Court ruling involving disability benefits was at issue in Chronister v. Unum Life Ins.Co. of America, 2009 U.S.App.LEXIS 9033 (8th Cir. April 30). This ruling marked the second time the 8th U.S. Circuit Court of Appeals had occasion to consider Sandra Chronister’s application for disability benefits. In the first […]
A recent ruling from the 6th U.S. Circuit Court of Appeals, DeLisle v. Sun Life Assurance Company of Canada, 2009 U.S.App.LEXIS 4251 (March 4), illustrates how courts are now engaging in a more probing and thorough review of ERISA benefit denials. Sherry DeLisle, who sustained significant injuries in an automobile accident, was fired from her […]
Functional capacity evaluations are frequently used in disability insurance evaluations. While some courts have deemed such testing reliable, Alfano v. Cigna Life Ins.Co. of N.Y., 2009 U.S.Dist.LEXIS 7688 (S.D.N.Y. Jan. 30), offers an object lesson as to why courts need to be careful in assessing such tests. The plaintiff in Alfano worked in an administrative […]
A recent 2d U.S. Circuit Court of Appeals ruling, Slupinski v. First Unum Life Insur. Co., 2009 U.S.App.LEXIS 1157 (Jan. 23), offers a textbook lesson on attorney’s fee awards as well as the propriety of prejudgment interest awards under ERISA.