Truitt v. Unum Life Ins. Co. of America

Unum denied plaintiff's claims of long-term disability and sought more than $1 million in reimbursements for benefits paid. Unum denial was based on emails it had received from plaintiff's former companion indicating that plaintiff was engaged in activities that were inconsistent with her asserted disability. The district court found that there was substantial evidence to support Unum's denial of benefits, but, nonetheless, held that the denial was procedurally unreasonable because Unum did not fulfill its duty to "consider the source" of the emails. The court concluded that, in evaluating whether a plan administrator wrongfully denied benefits under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., it has never imposed a duty to investigate the source of the evidence. The court held that the burden was on the claimant to discredit evidence relied on by the plan administrator. Accordingly, the court reversed the judgment of the district court, finding that Unum did not act arbitrarily and capriciously in denying plaintiff benefits. View "Truitt v. Unum Life Ins. Co. of America" on Justia Law