Bernard v. Kansas City Life Insurance Co., No. 20-1593 (8th Cir. 2021)
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After plaintiff admitted to using fentanyl at work, he was terminated from his position as a certified nurse anesthetist at Mid-Missouri. Plaintiff then submitted claims for short- and long-term disability benefits to Kansas City Life, which issued disability insurance policies to Mid-Missouri as part of its employee benefit plan.
The Eighth Circuit affirmed the the district court's conclusion that Kansas City Life had abused its discretion in denying plaintiff benefits under the Employee Income Security Act of 1974 (ERISA). The court concluded that Kansas City Life's denial of benefits is not supported by substantial evidence where reasonable minds could not reconcile Kansas City Life's position that plaintiff was unable to safely administer anesthesia on October 6, 2017, with its position that he had safely administered anesthesia while under the influence of fentanyl during the time period between his relapse and termination. Therefore, the evidence that plaintiff made no medical errors and did not seek treatment until after he was terminated, as well as the fact that the record does not disclose his exact date of disability, could not support Kansas City Life's conclusion that plaintiff was not disabled before his insurance coverage ended.
Court Description: [Wollman, Author, with Colloton and Shepherd, Circuit Judges] Civil case - ERISA. Plaintiff was terminated from his position as a nurse anesthetist after he admitted using fentanyl at work. He applied for short- and long-term disability benefits based on addiction, and the plan denied coverage on the ground plaintiff was not disabled at the time of his termination. The district court determined the plaintiff was entitled to benefits as his addiction rendered him incapable of performing the duties of his position. Held: the plan's decision to deny benefits was not supported by substantial evidence; the evidence that plaintiff made no medical errors, did not seek treatment and could not determine the exact date of his disability did not support the plan's determination that he was not disabled before his coverage ended.
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