Seventh Circuit Upholds Fund’s Denial of Disability Pension Benefits Under ERISA Due to Lack of Connection to a Workplace Injury

In Lane v. Structural Iron Workers Loc. No. 1 Pension Tr. Fund, No. 22-1149, __F.4th__, 2023 WL 4554097 (7th Cir. July 17, 2023), Plaintiff-Appellant Jeffery Lane sought a disability pension benefit under the Structural Iron Workers Local No. 1 Pension Trust Fund after a combination of injuries rendered him disabled from his job as a union iron worker. To qualify for benefits given his nine credits as a union iron worker, he must be “totally and permanently disabled as the result of an accident sustained while on the job and employed by a Contributing Employer as an Iron Worker.” The Trustees of the Fund denied his claim for benefits on the basis that there was not enough evidence connecting his disability to his on-the-job injuries. If Plaintiff had at least fifteen credits, the Social Security’s determination of disability would have met the Fund’s definition of “totally and permanently disabled” and he would receive benefits. But because he did not have enough credits, he had to show that the disability was caused by a workplace injury.

The Seventh Circuit first considered Plaintiff’s argument that Fund’s failure to provide him with a copy of the independent medical examiner’s report before denying his appeal violated ERISA regulation, 29 C.F.R. § 2560.503-1(h)(4) (requires that a claimant be provided the opportunity to review and comment on all of the materials an administrator might consider before deciding the claim). Though normally this procedural violation would require a remand to the administrator so that the claimant can respond to the new evidence, Plaintiff did not make this argument to the district court. As such, Plaintiff waived this argument on appeal.

On the substance of the Fund’s decision, the Seventh Circuit explained that because the Fund’s Plan gives the administrator discretionary authority, the Fund’s decision will be upheld if it is supported by reasoned explanation based on the evidence. Here, the court found that the Trustees reasonably concluded that Plaintiff was not entitled to benefits because the evidence did not show that Plaintiff’s workplace injury caused his total and permanent disability. The Trustees were reasonable in focusing on the Social Security Administration’s decision, which did not conclude that his disability was caused by the workplace accident. Though the Trustees could have gathered more evidence to support Plaintiff’s claim, they did not have a duty to do so since the “[r]esponsibility for any undiscovered evidence lies with Lane.” “[M]uch like judges, plan administrators are not pigs hunting for truffles.” The court found that the Plan required that a claimant be entitled to disability payments under the Social Security Act as a result of an accident sustained on the job; it is not enough to have a “work-related disability.” It was reasonable for the Trustees to ask its independent reviewer whether the SSA award was connected to a workplace injury. Because the Trustee’s decision was reasonable, the court affirmed the district court’s entry of summary judgment for the Fund.