Tenth Circuit: Seventh Amendment’s Civil Jury Trial Guarantee Does Not Apply to ERISA Benefits Action

In Cruz v. Reliance Standard Life Insurance Company, No. 21-2018, __F.App’x__, 2021 WL 3889924 (10th Cir. Sept. 1, 2021), Plaintiff-Appellant Eldie Cruz, M.D. appealed the district court’s determination that he was not entitled to long-term disability benefits under a benefit plan insured by Defendant-Appellee Reliance Standard Life Insurance Company. The district court reviewed Reliance Standard’s decision de novo. Dr. Cruz appealed on the basis that under the Seventh Amendment of the U.S. Constitution he should have had an opportunity to present evidence about his medical records to a jury.

The Tenth Circuit noted that though ERISA does not explicitly deny a trial by jury, “an action to recover ERISA-governed benefits is equitable, not legal, and so does not fall within the Seventh Amendment’s civil jury trial guarantee.” The court was not sitting en banc so it cannot overrule the judgment of another panel. And there is no superseding Supreme Court authority which would enable the court to grant the relief he requests. The court affirmed the judgment of the district court.