Rodriguez-Lopez v. Triple-S Vida, Inc., No. 15-2413 (1st Cir. 2017)Annotate this Case
On her last day of work with Mova Pharmaceutical Corporation, Nilda Rodriguez-Lopez (Rodriguez) began experiencing symptoms. Rodriguez was diagnosed with several physical and mental conditions and filed a claim for long-term disability (LTD) benefits under Mova’s employee welfare benefits plan (the Plan). Triple-S Vida, Inc. denied Rodriguez’s application for LTD benefits, finding she did not meet the Plan’s definition of disabled. After she exhausted her administrative remedies, Rodriguez filed suit. The district court granted Triple-S’s motion for summary judgment, concluding that Triple-S’s denial of LTD benefits was neither arbitrary nor capricious. Rodriguez appealed, claiming that the Plan did not reflect a clear grant of discretionary authority to Defendant, and therefore, Triple-S’s determination to deny her LTD benefits was subject to the de novo standard of review. The First Circuit vacated the judgment, holding that the Plan did not confer discretionary authority upon Triple-S, and therefore, de novo review applied. Remanded.