Sixth Circuit Affirms Summary Judgment Against LTD Applicant Who Was Receiving SSDI

This morning, the Sixth Circuit Court of Appeals affirmed summary judgment in favor of an insurance company which denied long-term disability benefits to an employee who claimed that she could not work (and was successful in obtaining SSDI benefits), but whose medical providers had periodically released her to return to work.  Frazier v. LINA, No. 12-6216 (6^th Cir. 8-5-13).  The Court found that the employer’s LTD insurance policy at issue named the insurance company as a fiduciary and could be considered as the plan document, not merely an asset of the plan.  The Court also found that the plan vested discretionary authority in the insurance company when it required employees to submit “satisfactory proof” of their disability to the insurer.  “This Court has found ‘satisfactory proof,’ and similar phrases, sufficiently clear to grant discretion to administrators and fiduciaries.  . . Although the Policy could have more clearly expressed this grant of discretion, the ‘mere fact that language could have been clearer does not necessarily mean that it is not clear enough.’”  The decision was clearly rational to deny benefits (meaning it must be affirmed) because, among other things, the employee’s own doctors had released her to return to work without restrictions at various points.  Finally, the Court found the insurance company had the discretion to assist the employee with her SSDI application and was not mandated by the policy to assist her.

 NOTICE: This summary is designed merely to inform and alert you of recent legal developments. It does not constitute legal advice and does not apply to any particular situation because different facts could lead to different results. Information here can change or be amended without notice. Readers should not act upon this information without legal advice. If you have any questions about anything you have read, you should consult with or retain an employment attorney.