Harrison v. Wells Fargo Bank, N.A., No. 13-2379 (4th Cir. 2014)Annotate this Case
Plaintiff filed suit against Wells Fargo under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132, alleging that the company improperly terminated her short-term disability benefits while she was undergoing a series of treatments for thyroid disease. The district court found insufficient evidence of disability under the Plan to conclude that Wells Fargo abused its discretion in denying plaintiff's claim. The court held that Wells Fargo failed to meet its statutory and Plan obligations to plaintiff as a beneficiary. By failing to contact plaintiff's psychologist when it was on notice that plaintiff was seeking treatment for mental health conditions and when it had his contact information, as well as properly signed release forms from plaintiff, the plan administrator chose to remain willfully blind to readily available information that may well have confirmed plaintiff's theory of disability. Accordingly, the court reversed and remanded with directions to return the case to Wells Fargo for a full and fair review of plaintiff's claims.