Tuesday, August 11, 2009

Eleventh Circuit on a Variety of ERISA Issues

In Ruple v. Hartford Life & Accident Insurance (09-11287), the Eleventh Circuit addressed a number of ERISA issues. You can find Roy Harmon's post at the Health Plan Law blog on the case here. The issues discussed follow:

1. Citing to, among other cases, Metro. Life Ins. Co. v. Glenn, – U.S. –, 128 S.Ct. 2343 (2008), the Eleventh Circuit addressed the test to be used to review an administrators decision:
This court uses a multi-step analysis to guide these reviews of Administrator decisions and the various standards of review. HCA Health Services of Georgia, Inc. v. Employers Health Ins. Co., 240 F.3d 982, 993-95 (11th Cir. 2001). The analysis involves six steps: (1) Apply the de novo standard to determine whether the claim administrator’s benefits-denial decision is “wrong” (i.e., the court disagrees with the administrator’s decision); if it is not, then end the inquiry and affirm the decision.
In a footnote, the court stated: "Because we decide this case at the first step of the analysis, see infra, we need not determine the level of discretion held by Hartford."

2. The Court applies the terms of the Policy

Additionally, when the court makes its own determination of whether the administrator was “wrong” to deny benefits under the first step of the Williams analysis, the court applies the terms of the policy.

3. Review is Limited to Administrative Record

Our law is clear, however, that even under the first step of the BellSouth analysis, where the court determines whether the administrator was wrong under a “de novo” standard, “[w]e are limited to the record that was before [the administrator] when it made its decision.” Glazer v. Reliance Standard Life Ins., 524 F.3d 1241, 1247 (11th Cir. 2008); Jett, 890 F.2d at 1139. Accordingly, the Magistrate Judge appropriately refused to allow Ruple to submit new evidence not contained in the administrative record before Hartford.
4. The Social Security Admistration's Determination Does Not Control ERISA Determination

The Social Security Administration’s determination that an individual is or is not disabled under its statutes and regulations does not dictate whether that same individual is disabled under the terms of an ERISA policy. Whatley v. CNA Ins. Cos., 189 F.3d 1310, 1314 n.8 (11th Cir. 1999).
5. Burden of Proof is on Claimant
Although Ruple acknowledges that the burden ordinarily rests with the person claiming benefits under an ERISA plan, see Horton v. Reliance Standard Life Ins. Co., 141 F.3d 1038, 1040 (11th Cir. 1998), he contends that because Hartford once gave benefits the burden shifts to Hartford to prove that he is no longer entitled to benefits. Ruple relies on Levinson v. Reliance Standard Life Ins. Co., 245 F.3d 1321 (11th Cir. 2001) to support his argument that the burden shifts to the administrator to disprove disability once the administrator has begun paying benefits. We disagree with Ruple’s reading of Levinson.


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