Roehr v. Sun Life Assurance Co. of Canada, No. 21-1559 (8th Cir. 2021)
Annotate this Case
After the termination of disability benefits under a long-term disability plan governed by the Employee Retirement Income Security Act (ERISA), plaintiff filed suit against the plan administrator, Sun Life, seeking reinstatement of long-term disability (LTD) benefits.
The Eighth Circuit reversed the district court's grant of Sun Life's motion for judgment on the record, concluding that there is no substantial evidence in the joint administrative record to support Sun Life's termination decision. In this case, the plan relied on virtually the same medical records for a decade while it paid the benefits, and has pointed to no information available to it that altered in some significant way its decision to pay benefits. The court explained that Sun Life's about-face requires "relevant evidence" that a "reasonable mind might accept as adequate to support" its change in decision, which the evidence does not in this record. Accordingly, the court directed the district court to order the reinstatement of plaintiff's LTD benefits.
Court Description: [Erickson, Author, with Kelly and Grasz, Circuit Judges] Civil case - ERISA. The district court properly evaluated the termination of plaintiff's long-term disability benefits under the abuse-of-discretion standard; here, the plan relied on virtually the same medical records for a decade while it paid the benefits, and has pointed to no information available to it that altered in some significant way its decision to pay benefits; such an about-face requires "relevant evidence" that a "reasonable mind might accept as adequate to support" the change in decision; here, that evidence does not exist in the record, and the district court decision affirming the termination of benefits is reversed; remanded with direction to the district court to order reinstatement of benefits as of the date of termination.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.