by Steve Fields | August 1st, 2022
July 29, 2022, U.S. Court of Appeals – 11th Circuit – Citation Pending
This ERISA Long Term Disability claim discusses the varying standards of review and the corresponding discovery issues. In this particular case, the claimant argued that because their claim was subject to a de novo standard of review that they should have been able to introduce additional evidence that was not included in the administrative record. The district court denied introduction of the additional evidence and granted Defendant’s motion for summary judgment, dismissing Plaintiff’s claim. The 11th Circuit Court of Appeals reversed that decision, finding that the district court erred by not considering additional information with the de novo standard of review.
This case presents an analysis of the varying positions different circuits have taken on these issues and highlights two important issues in ERISA Long Term Disability claims. The first is the applicable standard of review. Sometimes there is no dispute over the applicable standard of review for the Court, and other times, the parties cannot agree on how the Court must review a claim and the associated denial. The policy language, the timing of the claim, and various statutes all factor into what standard of review applies. The second issue this case highlights is that of discovery. Many cases will have a court review limited to the administrative record – that is the record from the beginning of the Long Term Disability claim until the final administrative denial. It is important to make sure that record is complete. There are limited angles to take to expand the evidence beyond the administrative record. These are important and nuanced issues that can play an important role in a Long Term Disability claim. If this issue comes up, it is important to review if expanding the record is possible and also if it is helpful.
Our attorneys are ready to help assess these important issues for you and move your claim forward toward the best possible outcome.
