Melissa McIntyre v. Reliance Standard Life, No. 22-1296 (8th Cir. 2023)
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Plaintiff sued Reliance Standard Life Insurance Company under 29 U.S.C. Section 1132(a)(1)(B), seeking to recover long-term disability benefits. The district court granted Plaintiff’s motion for summary judgment and denied Reliance’s cross-motion. Reliance appealed, and the Eighth Circuit reversed.
The court explained that the cases cited do not demonstrate that Reliance has a history of biased claims administration. Nor do they show some other systemic flaw in its claims review process that affected Reliance’s review of Plaintiff’s claim. On the other hand, Reliance does not argue that it maintained structural separations to minimize its conflict of interest. Therefore, the conflict of interest, in this case, deserves “some weight,” but the court concluded that it does not indicate that Reliance abused its discretion. The court wrote that substantial evidence supports Reliance’s decision, and neither the decisional delay in this case nor the purported conflict of interest leads us to conclude that Reliance abused its discretion.
Court Description: [Gruender, Author, with Colloton and Melloy, Circuit Judges] Civil case - ERISA. For the court's prior opinion in the case, see McIntyre v. Reliance Standard Life Ins., 972 F.3d 955 (8th Cir. 2020), where the court remanded the matter for application of the sliding scale abuse of discretion standard; on remand, the court again awarded plaintiff benefits, finding that the defendant's delay in deciding her appeal was an egregious procedural irregularity that violated ERISA's clear mandates, that defendant had a conflict of interest, and that the denial of benefits was not supported by substantial evidence. The defendant appeals. Held: defendant's decision to deny benefits and conclusion that plaintiff could work a sedentary full-time job was supported by substantial evidence; decisional delay and defendant's possible conflict of interest as the evaluator and payor did not lead to a conclusion that defendant abused its discretion in denying the claim for long-term disability benefits. Judge Melloy, dissenting.
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