Kutten v. Sun Life Assurance Co., No. 13-2559 (8th Cir. 2014)
Annotate this CasePlaintiff filed suit against Sun Life, alleging that Sun Life improperly denied him long-term disability benefits under a disability plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. The court concluded that it was reasonable for Sun Life to conclude that plaintiff's vitamin A supplements constituted a "medical treatment." The court held that Sun Life did not abuse its discretion in denying plaintiff's claim for benefits under the Plan, in light of an ordinary understanding of what constitutes a "medical treatment" and the purpose of the Pre-Existing Condition clause. Accordingly, the court reversed the district court's entry of summary judgment to plaintiff and remanded for entry of summary judgment to Sun Life.
Court Description: Civil case - ERISA. The district court erred when it determined that the insurer abused its discretion in construing the pre-existing condition clause to apply to Kutten's taking of supplements to treat his retinitis pigmentosa as it was reasonable for the insurer to conclude the vitamin A supplements constituted a medical treatment. Judge Bye, dissenting.
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