McIntyre v. Reliance Standard Life Insurance Co., No. 19-2367 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit vacated the district court's grant of summary judgment in favor of the plan beneficiary in an action arising under the Employee Retirement Income Security Act (ERISA). The court held that the district court erred in reviewing Reliance's denial of long-term disability benefits de novo rather than for an abuse of discretion. The court explained that the administrator's decisional delay on appeal does not in and of itself trigger de novo review. Rather, under circuit law, de novo review is not triggered in this context unless the administrator wholly fails "to act on an appeal" and that failure "raises serious doubts about the result reached by the plan administrator" in its initial denial. The court remanded for the district court to review Reliance's benefits decision for an abuse of discretion.
Court Description: [Gruender, Author, with Wollman and Kobes, Circuit Judges] Civil case - ERISA. The district court erred in reviewing the plan administrator's decision to deny long-term disability benefits de novo rather than for an abuse of discretion, and the district court's judgment for the plan beneficiary is vacated; decisional delay does not in an of itself trigger de novo review; remanded to permit the district court to review defendant's benefits decision for an abuse of discretion consistent with this circuit's precedents.
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