Marcin v. Reliance Standard Life Insurance Co., No. 16-7125 (D.C. Cir. 2017)Annotate this Case
Reliance challenged the district court's award of disability benefits to plaintiff under a plan pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., and the amount of benefits owed. The DC Circuit affirmed, holding that plaintiff proved partial disability. In this case, the conflict of interest factor in the standard of review, as well as plaintiff's medical record, lack of full time work, and release to return to work only "as tolerated" convinced the court that she established partial disability. The court explained that, according to the express terms of the Plan, partial disability was equivalent to total disability within the relevant period.