Reliance Standard Life Insurance Company recently prevailed in a long-term disability dispute in the Eleventh Circuit Court of Appeals. In Wright v. Reliance Standard Life Ins. Co., No. 19-14643, –F.App’x–, 2021 WL 303428 (11th Cir. Jan. 29, 2021), the Court of Appeals reviewed Reliance Standard’s denial of benefits which it made as an ERISA plan administrator.
The basic facts are as follows: Wright worked as the Vice President of Health Information Services at Integrity Health Care. Her job required light physical exertion. Integrity Health Care provided Wright with long-term disability and life insurance benefits.
Wright stopped working in 2017 and made a long-term disability insurance claim and a waiver of premium for life insurance claim with Reliance Standard. To qualify for long-term disability benefits, Wright had to show she could not perform the substantial and material duties of her job for 90 days in a row. The life insurance policy required “total disability” which it defined as the “complete inability to engage in any type of work for wage or profit for which [she was] suited by education, training, or experience.” The insurance polies gave Reliance Standard “discretionary authority to interpret” the policy terms and “to determine eligibility for benefits.”
At the time of Wright’s claims, the Court noted that the evidence showed “mixed indicators of disability” and treating physicians disagreed as to whether she was disabled. The court noted that:
On the one hand, Wright complained of pain and fatigue and was diagnosed with a constellation of health problems, including fibromyalgia, dysautonomia, and Postural Orthostatic Tachycardia syndrome. On the other hand, repeated physical exams found her to exhibit normal strength, range of motion, and neurological and psychological condition.
Reliance Standard denied both claims on the basis that the medical evidence did not establish that she met the criteria for disability. Wright appealed the denial, after which time she saw her own independent doctor and one chosen by Reliance Standard. Her doctor concluded that she was “totally and permanently disabled.” And with no surprise, Reliance Standard’s doctor determined that she was capable of “full-time work duties and activities.” Reliance Standard then got a doctor to review all the records, and that doctor concluded that with some accommodations and limitations on her physical exertion, that Wright could work a regular schedule.
Based on this, Reliance Standard denied Wright’s ERISA appeals and she filed suit under ERISA, which provides that a civil action may be brought “by a … beneficiary” to “recover benefits due to [her] under the terms of [her] plan, to enforce [her] rights under the terms of the plan, or to clarify [her] rights to future benefits under the terms of the plan.” 29 U.S.C. § 1132(a)(1)(B).
Reliance Standard ultimately prevailed in the district court after the court found that Reliance Standard’s decision was not arbitrary and capricious. “It explained that Reliance reasonably weighed the competing evidence regarding Wright’s disability and that many test results and medical reports suggested that Wright’s health was relatively normal and that she was functioning well enough to work. It also noted internal contradictions in Wright’s evidence—such as one doctor simultaneously claiming that Wright was so dysfunctional as to be possibly bedridden while also recommending to her a vigorous exercise program with few limitations.”
Even though the district court acknowledged that Reliance Standard had a financial conflict of interest as both the payor of claims and the decisionmaker, the court found that there was overwhelming support for its decision.
Unfortunately for Wright, the Court of Appeals agreed with the district court for similar reasons. It noted her normal exam findings, her doctor’s prescription of a “rigorous exercise program” and the doctors’ disagreement as to her ability to work.
The court distinguished this case from that in Oliver v. Coca Cola Co., where the Court held that a discretion-vested administrator wrongfully denied a disability claim where it demanded “objective evidence” of the claimant’s chronic pain. The court found the facts in Oliver to be more compelling in terms of proof of disability and that the only doctor who found Oliver to not be disabled was one who did not evaluate him in person. In this case, one of Wright’s own doctors concluded she was not disabled. In the ERISA context, the Court of Appeals must determine whether the district court’s conclusion was supported by the administrative record regardless of how it arrived there. The Court concluded that the district court was correct in determining that Reliance Standard’s denial of Wrights’ long-term disability and life insurance claims were not arbitrary and capricious.
If you have a denied disability or life insurance claim with Reliance Standard Life Insurance Company, Roberts Disability Law may be able to help. Contact us today for a free consultation. These claims are difficult to navigate on your own; let us help you.
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