Green v. Union Security Ins. Co., No. 10-2924 (8th Cir. 2011)
Annotate this CaseAfter defendant denied plaintiff's claim for long-term disability benefits (LTD benefits), where plaintiff suffered from fibromyalgia, plaintiff filed a complaint against defendant pursuant to ERISA, 29 U.S.C. 1000 et seq. At issue was whether the district court properly granted summary judgment in plaintiff's favor finding that defendant had abused its discretion in denying benefits to plaintiff. The court held that the district court improperly determined that defendant abused its discretion when it ultimately denied the LTD benefits claim. Based on the record, there was more than a scintilla of evidence supporting defendant's conclusion that plaintiff's condition did not render him "disabled" under the policy's any occupation definition and defendant's decision was supported by substantial evidence, where a reasonable person could have reached a similar decision. The court also held that the fact that defendant operated under a structural conflict of interest, as both plan administrator and insurer, did not warrant a finding that defendant abused its discretion in denying plaintiff's claim. Accordingly, the court reversed summary judgment and remanded for further proceedings.
Court Description: Civil case - ERISA. The district court erred in finding the Plan Administrator had abused its discretion by denying Green's application for long-term-disability benefits as the functional capacity evaluation provided evidence in support of the Plan's decision, as did the medical opinions and a surveillance video; further, the district court erred in discounting the findings of a vocational expert that indicated Green could find gainful employment.
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