Employer had discretion to terminate former employee’s disability benefits where it had substantial evidence of no ongoing disability

An employer had no duty to continue providing long-term disability benefits to a former employee, a federal court in Arkansas ruled. The court granted the employer’s motion for judgment and dismissed the employee’s complaint, finding that the employer had conducted a full and fair review of the employee’s medical condition and had reasonably concluded that she was not disabled under the employee benefits plan.

The employee had worked for ConAgra Foods for over 30 years in a variety of finance positions and had participated in an employee benefits plan that provided for disability benefits. In 2000, the employee was diagnosed with breast cancer, which returned and went into remission over the next several years. In 2007, she began to experience fatigue and exhaustion, and ceased working in June 2008. She was later diagnosed with a serious heart condition, and doctors ultimately implanted a cardiac defibrillator. The employee continued to have physical health issues, and also suffered from a variety of mental health issues. In December 2008, she was granted long-term disability benefits under the employee benefits plan after a medical evaluation conducted on behalf of the employer concluded that she was disabled. She continued to receive disability benefits for several years.

The benefits plan provided that the employer could evaluate the employee’s condition periodically, and that the employee would continue to receive long-term disability benefits as long as she provided proof of continued disability and received appropriate and ongoing medical care. In January 2013, the insurer who served as the plan administrator began reviewing the employee’s disability status, and requested that she provide information and various records relating to her treatment.

The plan administrator, after several medical and mental health professionals reviewed the employee’s records and determined that she did not have a disability within the plan’s definition, informed the employee that she was no longer disabled under the plan and would no longer receive benefits. The employee’s appeal, which included additional documentation, was denied after review by additional medical professionals, who similarly concluded she was not disabled. Instead of filing a second appeal, as the employee was entitled to do, she filed a court action.

No abuse of discretion. The court rejected the employee’s assertion that the employer’s decision was unreasonable and unsupported by the medical evidence. The employee claimed that the employer’s denial of benefits relied primarily on the reports of two medical professionals, which she asserted were deeply flawed and had summarily dismissed the medical evidence she had submitted. The employee also claimed that the employer’s review and denial focused on the employee’s peripheral mental health issues rather than her cardiac issues and the physical basis of her disability. However, the court found that the employer had not abused its discretion by denying benefits because, under the plan, the employee had the burden of proving her continued disability, and she had not met that burden.

The employer had conducted a full and fair review before denying the employee’s appeal. The employer was entitled to follow the opinions of the independent reviewing physicians rather than the employee’s treating physicians, and there was no evidence that the reviewing physicians’ decisions were arbitrary or capricious. Nor was the employer’s review of the employee’s mental health issues a pretext for denying the employee’s claim, as the employee had characterized her mental health issues as a major part of her claim and the employer had also considered the employee’s physical issues. Additionally, the employer engaged new and independent medical professionals to evaluate the employee’s appeal, and did not grant deference to the initial decision. Both physicians evaluating the appeal reviewed all medical evidence submitted by the employee, found it insufficient to support a finding that she was disabled or unable to work in certain occupations, and explained why they thought the medical evidence was insufficient to support a claim of disability.

SOURCE: Thompson v. ConAgra Foods, Inc., (E.D. Ark), No. 1:14-cv-00041 KGB, October 7, 2016.

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