Fourth Circuit Affirms Win for Plaintiff in ERISA Long-Term Disability Lawsuit Against Reliance Standard

In Wonsang v. Reliance Standard Life Insurance Company, No. 24-1419, 2025 WL 1672860 (4th Cir. June 13, 2025), a dispute over entitlement to long-term disability benefits, the Fourth Circuit Court of Appeals affirmed the district court’s decision to grant summary judgment in Plaintiff-Appellee Wonsang’s favor. The court held that even under an abuse of discretion standard, Reliance Standard’s decision to terminate benefits was flawed due to its cherry-picking of medical evidence and Reliance Standard failed to issue a timely decision on Plaintiff’s appeal.

Wonsang, a former physical therapist assistant, filed for long-term disability benefits under a policy with Reliance Standard when her chronic neck and back conditions prevented her from working. Reliance Standard initially approved her claim but five years later it terminated her benefits based on paper medical reviews citing to “normal” findings and the fact that Wonsang had authored and published a book, activities which Reliance Standard interpreted to mean that Wonsang did have the cognitive capacity for work in any occupation. The policy required Reliance to pay benefits if Wonsang was “Totally Disabled,” which initially meant she could not perform her regular occupation and later, any occupation for which she was reasonably qualified.

The district court applied a de novo review rather than an abuse of discretion. This choice was because Reliance failed to comply with ERISA’s procedural requirements, forfeiting its discretionary authority under the policy. The court found that even under an abuse of discretion standard, Reliance’s decision to terminate benefits was flawed.

The court highlighted that every physician who evaluated Wonsang agreed she was incapable of any work due to severe spinal impairments, corroborated by MRI results. Reliance’s decision to terminate benefits was seen as improperly dismissing these consistent medical opinions. The court criticized Reliance for cherry-picking evidence and failing to address the comprehensive findings of Wonsang’s treating physicians.

Reliance’s failure to issue a timely appeal decision under ERISA’s deadlines was a critical factor. The court emphasized that this procedural oversight contributed to the forfeiture of Reliance’s discretionary review authority, necessitating a de novo review.

The court denied Reliance’s request for a remand to consider a self-reported conditions limitation. The court found that the comprehensive MRI evidence clearly verified Wonsang’s condition, making any remand unnecessary and futile.