Eleventh Circuit Affirms Denial of ERISA-Governed Short Term Disability Benefits, Finding Administrator’s Decision Was Not Arbitrary and Capricious

In Rubin v. Life Insurance Company of North America, et al., No. 24-10433, 2025 WL 689691 (11th Cir. Mar. 4, 2025), the Eleventh Circuit Court of Appeals upheld Life Insurance Company of North America’s (“LINA”) denial of Plaintiff Deborah Rubin’s short-term disability benefits, finding that the Magistrate Judge correctly granted summary judgment to LINA because LINA’s decision was a reasonable interpretation of the evidence in the claims record and LINA’s structural conflict of interest does not render its decision arbitrary and capricious. The court also determined that the Magistrate Judge correctly denied Plaintiff’s request for discovery outside the “administrative record.”

Plaintiff, a telephone sales representative for the National Federation of Independent Businesses, filed for short-term disability benefits in September 2021 due to anxiety and depression. Her claim was governed by a policy with LINA, which required claimants to demonstrate an inability to perform their job and earn a significant portion of their income due to their condition. LINA, vested with discretion under the plan to interpret its terms and decide on claims, requested medical records from Plaintiff’s physician, Dr. Richard Phelps. However, the initial response from Dr. Phelps did not provide sufficient evidence of a disabling condition, citing Plaintiff’s role as a caretaker for her husband rather than her own incapacity.

LINA denied Plaintiff’s claim in December 2021, pointing out the lack of psychiatric impairment evidence in her medical records. Plaintiff appealed, but further reviews by LINA, including evaluations by its Medical Director, Dr. Bahar Golestan, and later by another specialist, Dr. Divya Hedgren, reinforced the initial denial. These reviews highlighted that Plaintiff’s own activities, such as caregiving and overseeing a condo renovation, were inconsistent with her claim of disability.

The court applied a six-step framework for ERISA claims, ultimately determining that LINA’s decision was reasonable and supported by the administrative record. Despite Plaintiff’s arguments of a structural conflict of interest due to LINA’s dual role as insurer and administrator, the court found no evidence that this conflict influenced the decision unjustly. The court noted that Plaintiff failed to provide proof of LINA’s alleged bias, and the medical evaluations conducted were thorough and justified the denial based on the evidence available.

Additionally, the court denied Plaintiff’s request for discovery outside the administrative record, as the court’s review was limited to the information available to LINA at the time of its decision. The court affirmed the Magistrate Judge’s ruling to exclude additional discovery, aligning with precedent that such reviews focus on the reasonableness of the administrator’s decision based on existing records.

In conclusion, the Eleventh Circuit affirmed the district court’s summary judgment in favor of LINA, finding that the denial of Plaintiff’s short-term disability claim was not arbitrary or capricious.