ERISA Plaintiff granted disability benefits from Prudential for depression and anxiety
Hughes v. Prudential Life Insurance Co. U.S. District Court for the Western District of Va.
After being suspended from his employment, the plaintiff, Mr. Hughes, advised his employer that he was unable to return due to Depression and Anxiety. He subsequently claimed that, due to his mental condition, he was unable to return to work in any capacity. Accordingly, he filed for disability benefits. Under the disability policy provided to Mr. Hughes by his employer, in order to be considered “totally disabled”, the employee has to provide “due proof” that he is “wholly, continuously and permanently unable to engage in any occupation or perform any work for any kind of compensation of financial value during the remainder of his lifetime.”
Mr. Hughes’ treating physician, Dr. Murdock, indicated that the plaintiff had to stop working as the result of acute depression and anxiety. However, in response to a question posed to him by Prudential, Dr. Murdock acknowledged that Mr. Hughes had a previous bout with depression in the past. Prudential denied the plaintiff’s claim for benefits on the basis that he was able to recover from depression in the past.
The Plaintiff appealed Prudential’s denial and provided additional information and records from another medical doctor and a licensed clinical social worker, both of whom confirmed his inability to return to his job, move to another job or train for another job in the foreseeable future. Despite the additional information, Prudential upheld its previous denial and emphasized that the plaintiff was able to recover from depression the past. Additionally, Prudential relied on the opinion of Dr. Gross, whom they retained to review the plaintiff’s medical records. Dr. Gross diagnosed the plaintiff with an episode of recurrent major depression, but he noted the array of treatment options available to the plaintiff and ultimately determined that there was no clinical basis to conclude that he could not return to work.
Pursuant to the Employee Retirement Income Security Act (ERISA), Mr. Hughes filed a lawsuit. The Court, upon review of the record, concluded that Prudential improperly denied the plaintiff’s claim. In the Court’s opinion, the plaintiff provided sufficient evidence to establish that he suffers from depression and anxiety and that his depression and anxiety render him totally and permanently disabled. While the Court acknowledged that it cannot require plan administrators to automatically accord special weight to the opinions of a claimant’s treating physicians, plan administrators “may not arbitrarily refuse to credit a claimant’s reliable evidence, including the opinions of a treating physician.” Based on the fact that Prudential ultimately relied upon Dr. Gross’s evaluation to deny the plaintiff’s claim and since Dr. Gross did not actually examine the plaintiff or perform any type of clinical interview, the Court did not find Dr. Gross’s evaluation to be persuasive. Accordingly, the plaintiff’s motion for summary judgment was granted and the defendant’s motion for summary judgment, denied.