by Steve Fields | June 21st, 2022
May 11, 2022 – U.S. Court of Appeals – 7th Circuit – 33 F.4th 949 2022
Canter worked as a premises technician for an AT&T subsidiary before his disability benefits claim began. He began suffering from migraines, lightheadedness and dizziness, and Canter alleged that he could no longer perform his heavy-duty occupation, which included working at heights up to 28 feet off the ground. His claim for Short Term Disability benefits was approved for several months before being denied by the plan administrator.
Of note, the plan under which this claim for disability benefits was made states that a claim “must be supported by objective Medical Evidence,” which “includes, but is not limited to, results from diagnostic tools and examinations performing in accordance with the generally accepted principles of the health care profession.” The Plan identifies a failure to provide this “objective medical evidence” as grounds to deny a claim.
While Canter’s treating physicians were generally supportive of his inability to perform his occupation based on his symptoms, the diagnostic tests used and found in the medical records came back “normal” or “unremarkable,” at least as they related to his disabling conditions. Sedgwick, acting as the claim administrator for Canter’s claim, hired a doctor to “independently” review the medical evidence. This hired doctor determined that the claim was not supported by objective medical evidence, and Sedgwick relied on that to deny Canter’s claim. Despite various pieces of medical evidence supporting Canter’s claim, Sedgwick relied on the reports of the hired doctors to uphold the denial of the claim during the internal administrative appeal.
The district court and the 7th Circuit Court of Appeals found in favor of the Plan in upholding the denial of Canter’s claim. The courts relied on the fact that the claim was subject to an abuse of discretion standard of review, and that even though there might be some evidence that contradicts the findings and determination made by the Plan, their decision was reasonably supported and must be upheld.
This case also dealt with the issue of the limited administrative record. Noting that the record for judicial review is typically limited to the administrative record compiled during the administrative claim stage, the Court found that the narrow exceptions to this rule did not apply.
ERISA disability claims often hinge on the interpretation and application of policy provisions. It is vital to have a deep understanding of the policy that governs your claim. It is also vital to get as much support as possible into your administrative record before you need to get into a lawsuit with your disability claim insurance carrier. This is why we build the strongest claims possible for our clients during each and every appeal. Not only does it give you the best chance to win your appeal in the first place, but you are better set up if you do end up needing to proceed with a lawsuit. No matter where your claim is at, our attorneys are happy to assist you in moving your claim forward and giving you the best chance of success possible.
