In Anderson v. Sappi Fine Paper of North America, plaintiff worked for Sappi for 30 years as a carton line operator during which time she suffered continuously from chronic pain due to her club feet. Her job required her to stand for several hours a day. After she fractured her foot while on vacation, she quit work and filed a claim for disability asserting that due to her long-term feet and knee problems, she could no longer stand long enough each day to do her job. She was examined by several different specialists who did not say she could no longer work, but instead recommended Sappi provide her accommodations so she could work.
The plaintiff raised three separate issues in the Minnesota court: 1) Sappi erred in denying her claim; 2) Sappi had a conflict of interest since it was both the payor of benefits and gatekeeper as the one who decided who received benefits; and 3) Under Sappi’s definition of disability, no none could ever meet it.
Federal District Court Upheld Sappi’s Denial of Disability Benefits
Anderson claimed she was disabled from performing her job with Sappi and used the fact that the Social Security Administration had granted her disability benefits as support for her claim. The court noted that since the SSA used a different definition of disability, that fact was not relevant. It noted that even SSA’s award of benefits included the caveat that she could do sedentary work.
In upholding Sappi’s decision, the court stated: “Sappi was not tasked with weighing conflicting medical opinions. Absent from the record is any opinion from any physician that examined Anderson who determined that she was unable to work without an accommodation.” Since the medical evidence did not support her claim that she could not do her job, the court upheld Sappi’s denial of disability benefits.
Court Finds No Conflict of Interest
Anderson claimed Sappi had a conflict of interest since it was both the gatekeeper who decided who was granted benefits and the payor of those benefits. She alleged that this conflict caused them to arbitrarily deny her claim. The court noted that “the conflict of interest is readily apparent.” Even so, it deemed that is not enough. A claimant must show a “history of biased claims administration.” Claimant here was able to locate only one decision from “nearly a decade ago” to support her claim. That was simply not enough evidence to establish a history of bias.
Disability Definition That is “Exceedingly Difficult to Meet” Cannot be Rewritten by the Court
Sappi’s definition of disability according to its policy language is when someone is: “unable to engage in any occupation or perform any work for any kind of compensation of financial value.” The court expressed sympathy with the plaintiff who had persevered and worked in chronic pain for 30 years and who had “well-documented multiple medical conditions.”
But, despite her medical problems, the court upheld the contract language, holding that, “Although exceedingly difficult to meet, the law does not compel Sappi to have a more favorable definition of disabled; the law does not even require Sappi to have a plan at all.”
This case was not handled by our office, but it may provide claimants guidance when they want to pursue disability benefits but their medical records do not support their claim, and to those who have an issue regarding a conflict of interest with their employer who is also their insurer. If you need assistance with a similar matter, please contact any of our lawyers for a free consultation.