Justia ERISA Opinion Summaries

After Prudential denied plaintiff's claim for long-term disability benefits, plaintiff subsequently filed suit against Prudential under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The district court granted summary judgment for Prudential. Because the Plan expressly grants Prudential discretionary authority, the court held that the district court correctly reviewed Prudential’s denial for an abuse of discretion. As such, the court's de novo review of the district court's summary judgment ruling will also apply the abuse of discretion standard. The court concluded that, in light of this record, plaintiff has failed to raise a genuine dispute of material fact that Prudential abused its discretion in denying his claim for long-term disability benefits. Prudential acknowledged that while plaintiff does have depression and anxiety, typically depression and anxiety do not cause large changes in cognitive function, and in plaintiff's case, there is no evidence of valid cognitive impairment from any source. Accordingly, the court affirmed the judgment. View "Burell v. Prudential Ins. Co." on Justia Law

Plaintiff filed suit against Aetna and Hewlett Packard to recover benefits as the beneficiary of her husband’s group life insurance plan under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)(B). On appeal, plaintiff challenged the district court's final judgment affirming the decision of the ERISA plan administrator to deny benefits. The court concluded that plaintiff has not provided evidence that suggests that the method by which Aetna made its determination in her case was procedurally unreasonable; the court rejected plaintiff's claim that Aetna’s conflict should be given greater weight in the district court’s analysis because it has a history of biased claims administration; and evidence is sufficient to permit a reasonable mind to reach the conclusion that the husband's fall was due to or contributed to by illness. The court further stated that, even accounting for Aetna’s conflict of interest as both insurer and plan administrator, Aetna did not abuse its discretion in determining that the husband's fall was not a covered “accident” under the terms of the Policy, negating recovery under the Policy. Because Aetna's denial of plaintiff's claim was not an abuse of discretion, the court affirmed the judgment. View "Hagen v. Aetna Ins. Co." on Justia Law