In Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (1989), the U.S. Supreme Court ruled that benefit claims under the ERISA law should be evaluated under principles of trust law, which allows discretionary authority to be vested in trustees to determine eligibility to receive benefits and to interpret the plan documents. At the […]
A recent ruling from the federal court in Atlanta, Johnson v. Metropolitan Life Ins.Co., 2008 U.S.Dist.LEXIS 42944 (N.D.Ga. May 30, 2008), offered a very interesting and thorough analysis of a disability benefit dispute. In Johnson, the plaintiff, who had worked for Cingular for more than 13 years as a ”field coordinator, global accounts,” suffered from […]
In Caplan v. CNA Financial Corp., 2008 U.S.Dist.LEXIS 28290 (N.D.Cal. April 4), David Caplan, who worked for CNA Financial supervising workers’ compensation claims, suffered a neck injury, which caused severe pain, and spasms that significantly interfered with his ability to work at a computer, his primary job function. Initially, Caplan tried to deal with his […]
Two significant rulings issued days apart upheld the authority of state departments of insurance to prohibit life and disability insurers from including discretionary clauses in their policies that would have the effect of triggering an arbitrary and capricious standard of review under the ERISA law. At issue was the adoption by several states of a […]
After a district court awarded benefits to the plaintiff, the insurer successfully appealed to the 10th U.S. Circuit Court of Appeals, which issued a ruling narrowly constraining the scope of consideration of ERISA claims under the de novo standard of adjudication. Jewell v. Life Ins.Co. of North America, 2007 U.S.App.LEXIS 27832 (Nov. 30, 2007). The […]
In Shane v. Albertson’s Inc., 2007 U.S.App.LEXIS 24092 (9th Cir. Oct. 15), Stacey Shane originally qualified for disability benefits under Albertson’s ERISA-governed disability income plan in 2000 on account of a knee injury; and benefits were paid continuously for two years. However, benefits were terminated in 2003 when the Albertson’s Medical Review Committee determined Shane […]