Case Summaries

ERISA

[03/16] Schexnayder v. Hartford Life & Accident Ins. Co.
In an ERISA action claiming that defendant-insurer wrongly denied plaintiff disability benefits, summary judgment on the merits for plaintiff is affirmed where defendant's decision was procedurally unreasonable because the Social Security Administration (SSA) determined that plaintiff was fully disabled and unable to perform any work, but defendant did not address the SSA award in any of its denial letters. However, the district court's order granting plaintiff attorney's fees is reversed where the legal questions in this case were much closer than the district court credited, and the district court therefore abused its discretion in assessing attorneys' fees against defendant.

[03/10] Darvell v. Life Ins. Co. of N. Am.
In an ERISA action regarding defendant-insurer's denial of long-term disability benefits to plaintiff, summary judgment for defendant is affirmed where: 1) it was not an abuse of an ERISA plan administrator's discretion to ignore an opinion when the physician did not provide reliable objective evidence of testing or other proof to support a finding of long term disability; and 2) the plan administrator did not abuse its discretion by using the DOT description of plaintiff's occupation, rather than a description of his actual job duties.

[03/01] Jones v. Unum Provident Corp.
In an action under ERISA for wrongful denial of benefits, summary judgment for defendant is affirmed where: 1) defendant thoroughly investigated plaintiff's claim, both initially and when plaintiff appealed, and its initial and final decisions were carefully reasoned; and 2) coverage under the policy at issue lapsed more than six weeks prior to plaintiff's return to full-time work, and thus her later disability claim was not covered because of a pre-existing condition clause.

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