Waldoch v. Medtronic, Inc., No. 13-2543 (8th Cir. 2014)
Annotate this CasePlaintiff filed suit against his former employer, Medtronic, alleging that the company improperly denied his claim for benefits under a long-term disability plan governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court held that the district court did not abuse its discretion by admitting Medtronic's supplemental evidence for the limited purpose of determining the proper standard of review. The Plan provided Medtronic with complete and total discretionary authority to interpret and administer its provisions and this language is sufficient to trigger a deferential abuse-of-discretion standard of review and plaintiff failed to establish a procedural irregularity that would alter this standard or weigh in the court's consideration under it. Under this standard, the court agreed with the district court that Medtronic did not abuse its discretion in denying plaintiff's claim for "any occupation" long-term disability benefits. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil case - ERISA. Denial of benefits was properly reviewed under an abuse-of-discretion standard as the plan in question gave the administrator discretionary authority to determine eligibility and there were no serious procedural irregularities; the district court did not abuse its discretion by permitting defendant to submit supplemental evidence for the limited purpose of determining the proper standard of review; denial of benefits was not an abuse of the plan administrator's discretionary authority.
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