Hampton v. Reliance Standard Life Ins. Co., No. 13-2782 (8th Cir. 2014)
Annotate this CasePlaintiff filed suit against Reliance and the Plan, under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., claiming that Reliance abused its discretion in denying long-term disability benefits. The district court granted summary judgment to plaintiff. The court concluded that Reliance's interpretation of the Plan is reasonable. The loss-of-license provision states that the loss of a license for any reason is insufficient in and of itself to entitle a claim to benefits. In this case, plaintiff's diagnosis of diabetes mellitus was not enough by itself to justify benefits. Reliance's interpretation merely requires that the claimant show that the injury or sickness itself renders him unable to perform his occupation. Further, Reliance's determination that plaintiff was not totally disabled was supported by substantial evidence and its denial of benefits was reasonable. Accordingly, the court reversed the judgment of the district court.
Court Description: Civil case - ERISA. The insurer's interpretation of the Plan - that a claimant had to produce evidence that he was physically or mentally incapable of performing the duties of his occupation - was reasonable; while plaintiff lost his over-the-road truck license as a result of his diabetes mellitus, that by itself, was not enough to justify benefits; the insurer's determination that plaintiff was not totally disabled is supported by substantial evidence and the decision to deny benefits was reasonable. Judge Smith, dissenting.
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