This month’s Friday Five covers cases relating to implied terms in disability definitions, retrieving mistakenly paid pension payments, claims from former beneficiaries who were allegedly and improperly excluded from collecting benefits, whether a drug overdose triggers accidental death and dismemberment benefits, and personal jurisdiction issues.
- Sixth Circuit Grants Plan Leeway to Evaluate Definition of Disability With Implied Terms. In a recent long-term disability dispute, the parties jockeyed over the meaning of “total disability” under the plan documents. The plan at issue failed to expressly mention that a total disability had to impact the ability to work, but, instead, focused on how the illness was regarded in the medical profession or whether the condition required hospital care or home confinement. The Sixth Circuit, after deciding that the abuse of discretion standard applied, granted the plan leeway to imply that total disability meant that the claimant was required to establish an inability to work, not just that the claimant suffered from a serious medical condition. The Court reasoned that it was not its role under the applicable standard of review to pick the best explanation of the definition of disability under the plan and concluded that the plan’s view was not unreasonable under the circumstances. Lloyd v. Proctor and Gamble Dis. Bene. Plan, No. 20-4329, 2021 WL 4026683 (6th Cir. Sept. 3, 2021).
- Pension Plan Permitted to Clawback Payments Mistakenly Made to Deceased Pensioner. A former employee collected monthly pension payments up until his death in early 2016. The employer was unaware of the death and, pursuant to an option under the plan selected by the former employee just before his death, sent a lump sum check for almost $130,000 representing the remaining benefits to be paid over the entire term of the pension. The former employee’s estate objected when the plan cancelled the check upon discovering the interceding death. The court navigated around some of the estate’s more complicated arguments by crediting the plan’s reliance on a provision terminating payments upon death, while the court further refused to credit the estate’s argument that the pre-death election for a lump sum of future benefits changed the outcome or created any contractual arrangement to defeat the relevant provisions of the plan. Steward v. LSC Communications Pension Plan, No. 20-3166, 2021 WL 4244752 (N.D. Ill. Sept. 17, 2021).
- Court Refuses to Permit Former Beneficiary Allegedly Excluded From Life Insurance Proceeds to Sue Insurer. The plaintiff, proceeding pro se, told a twisted tale regarding how he was improperly removed as a beneficiary of, among other benefits, a life insurance policy of his deceased father. The court, in granting the insurer’s motion to dismiss, reasoned that ERISA only provides standing to current beneficiaries of a plan, not former ones. Additionally, the court dismissed the remainder of the plaintiff’s state law claims under the preemption provisions of ERISA. In the end, the court made short work of the pro se plaintiff’s claims and refused to keep the insurer in the case after it had already paid benefits to the listed beneficiaries. Koshnick v. Alight Solutions, No. 21-618, 2021 WL 4077564 (D. N.J. Sept. 8, 2021).
- Court Agrees With Administrator That Drug Overdose Dose Not Trigger Accidental Death and Dismemberment Provision. The plaintiff-beneficiary sued for accidental death and dismemberment benefits following a drug overdose death of his brother. The court agreed that the administrator did not abuse its discretion in denying benefits because the decedent’s self-administration of dangerous drugs was not unintended, unexpected, or unforeseen, which was required to establish a covered accident under the policy. Instead, the court noted that the decedent’s conduct was extremely dangerous. The plaintiff attempted to distinguish the claim by the decedent’s prior employment as a nurse anesthetist and argued that the decedent’s professional background made him qualified to safely administer the drugs to himself. The court, however, found the opposite and concluded that the decedent’s training should have further informed the decedent that injury or death was a distinct possibility. As such, the court granted summary judgment for the insurer. Baptiste v. Securian Financial Group, Inc., No. 20-60888, 2021 WL 3883707 (S.D. Fla. Aug. 31, 2021).
- Court Refuses to Allow Beneficiary to Drag Louisiana Employer Into Pennsylvania Federal Court. In a life insurance benefits dispute, the court granted a personal jurisdiction motion to dismiss filed by the employer, which was a Louisiana company without any business in Pennsylvania. The court credited evidence from the employer that its operations, and any alleged acts or omissions, occurred solely within Louisiana, and that the employer lacked any contacts at all with the Keystone State. The court also refused to expand or soften its jurisdictional analysis under ERISA. As such, the court dismissed the company, with prejudice, from the litigation. Williams v. Reliance Standard Life Ins. Co., No. 20-5036, 2021 WL 3852105 (E.D. Pa. Aug. 27, 2021).