Armani v. Northwestern Mutual Life Insurance Co., No. 14-56866 (9th Cir. 2016)
Annotate this CasePlaintiff filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., seeking judicial review of the denial of benefits under his long term disability policy sponsored by his employer and issued by Northwestern Mutual. The court held that the district court erred in denying plaintiff his long term disability benefits under the Plan where the administrative record plainly showed that plaintiff could not sit for more than four hours a day. Nonetheless, the district court upheld Northwestern Mutual’s determination that Armani could perform work at the “sedentary” level. The court agreed with other circuits and held that an employee who cannot sit for more than four hours in an eight-hour workday cannot perform “sedentary” work that requires “sitting most of the time.” Accordingly, the court vacated and remanded.
Court Description: Employee Retirement Income Security Act. The panel vacated in part the district court’s judgment in favor of the defendant in part in plaintiff’s action under the Employee Retirement Income Security Act, challenging a denial of benefits under a long term disability insurance policy. The administrative record showed that the plaintiff could not sit for more than four hours a day. The district court, reviewing de novo, nonetheless upheld the insurer’s determination that the plaintiff could perform sedentary work. The panel held that the district court erred by rejecting the plaintiff’s proposed definition of “sedentary” work on the basis that it was drawn from the Social Security context. Agreeing with other circuits, the panel held that an employee who cannot sit for more than four hours in an eight-hour workday cannot perform “sedentary” work that requires “sitting most of the time.” The panel vacated the part of the district court’s judgment denying the plaintiff his long term disability benefits and remanded for further proceedings. ARMANI V. NORTHWESTERN MUTUAL 3
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