Reliance Standard Disability Denial Upheld Due to Claimant's Lack of Strong Medical Record Support
In the case of Amy Wright v. Reliance Standard Life Insurance Company (Reliance), Plaintiff was the vice-president of health information services at Integrity Health Care when she stopped working on August 7, 2017. She brought claims for benefits under an LTD insurance policy and a waiver of premiums under a life insurance policy.
In order to be approved for LTD benefits, Plaintiff needed to prove she was unable to perform the material and substantial duties of her own job for 90 consecutive days. She was the vice-president of information services at Integrity Health Care, a job that was deemed to be sedentary.
To be eligible for waiver of premium payments for her life insurance policy, she needed to be unable to perform the duties of “any type of work” for which she was suited “by education, training or experience.” Both policies gave discretionary authority to Reliance to determine eligibility for benefits.
Plaintiff’s claim for benefits under both policies was based on, according to the Appeals Court, a “constellation of health problems” including diagnoses of fibromyalgia, dysautonomia, and Postural Tachycardia syndrome. The Appeals Court did not list all of her symptoms, noting that they had been all thoroughly described in the District Court opinion.
Despite these diagnoses, physical exams found Plaintiff to have “normal strength, range of motion, and neurological and psychological conditions.” She was exercising twice a week and her physician recommended she increase her exercise regimen.
Based on this evidence. Reliance denied both of Plaintiff’s claims. She administratively appealed. During the appeal process, Plaintiff was examined by two independent physicians. One was of her own choosing. This physician diagnosed more than a dozen medical ailments and found her “totally and permanently disabled.”
Reliance’s independent physician examined her and “acknowledged [Plaintiff’s] wide-ranging concerns” but only found some limitations to her range of motion and found she had an unsteady gait. This physician concluded that she was eligible for full-time work.
Reliance had another doctor review Plaintiff’s medical record. That doctor concluded that “with some accommodations and limitations on her physical exertion, [Plaintiff] could work a normal schedule.”
Reliance then upheld its original denial of Plaintiff’s claim. Having exhausted her remedies, Plaintiff then filed an ERISA lawsuit in the U.S. District Court for the District of Florida.
District Court Proceedings
In the District Court, Plaintiff alleged that Reliance acted arbitrarily and capriciously when it denied her claim to LTD benefits and waiver of premiums for her life insurance policy. She also alleged that Reliance had a conflict of interest since it was the entity that determined eligibility for benefits and the one that would pay. She claimed that Reliance ignored relevant medical evidence in favor of its own experts who “misunderstood the standard for disability.”
The District Court surveyed all the medical evidence and found that Reliance “reasonably weighed the competing evidence.” That Court noted that one doctor claimed simultaneously that Plaintiff was “bedridden” at the same time the doctor also recommended a vigorous exercise program.
The District Court also held that there was not a conflict of interest to a degree to render Reliance’s “decision arbitrary and capricious given the ‘overwhelming support in the medical evidence that [Plaintiff’s] condition is not as debilitating as claimed.’”
Plaintiff then filed an appeal with the U.S. Court of Appeals for the Eleventh Circuit.
Circuit Court Proceedings
The run-of-the-mill conflict of interest did not render the decision arbitrary and capricious. The Circuit Court noted that a conflict of interest is a “common feature of ERISA plans.” There must be more in order to establish that the conflict of interest rendered a decision arbitrary and capricious. In one case cited by Plaintiff, the claimant presented “more rigorous evidence” of disability.
In addition, in the case cited, the only doctors who asserted the claimant was not disabled were ones who never examined him. In this case, Reliance based its denial on reliable evidence from a doctor who did treat her in person and concluded she was not disabled.
Finally, the court concluded that “the district court was correct to conclude that Reliance’s denial of [Plaintiff’s] claims weren’t arbitrary and capricious.” Amy Wright v. Reliance Standard Life Insurance Company (Reliance), is a cautionary tale of why without proper documentation from treating physicians the disability insurance company will deny a claim for disability income benefits.
This case was not handled by our office, but we believe it can be instructive to those who are pursuing claims for disability and waiver of life insurance premiums to show the need of presenting strong medical evidence to the disability insurance company to support the claim. If you have questions about this case, or any question about your LTD policy, contact one of our disability attorneys at Dell Disability Lawyers for a free consultation.
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