Ms. Deborah Donovan, an input shift operator for Eaton Corp, was insured under the company’s self-funded group disability plan. Due to degenerative disk disease, chronic back pain and leg pain, Ms. Donovan filed a claim for total disability benefits in 1993.
After ten years of receiving disability benefits, Eaton terminated payment after an evaluation conducted by Broadspire Services Inc. Broadspire claimed there was no objective medical evidence proving Donovan was unable to work. Ms. Donovan appealed, submitting medical records from her doctor which contained evidence of chronic permanent lumbar radiculopathy and severe lumbar degenerative disk disease. Broadspire upheld its denial of benefits and claimed that Ms. Donavan could perform a sedentary occupation. Additionally, Broadspire claimed that a Functional Capacity Evaluation (FCE) proved that she could work.
After several more denied appeals, Ms. Donovan filed suit seeking reinstatement of benefits under the Employee Retirement Income Security Act (ERISA). Ms. Donovan was granted summary judgment, finding that she was entitled to benefits and Eaton appealed.
On appeal, the court upheld the grant of summary judgment, finding that Eaton’s denial of benefits was an abuse of discretion. After reviewing Donovan’s treating physician’s notes, the court concluded that Eaton’s decision to terminate benefits to a claimant with chronic leg and back pain was unreasonable.