Amy Silverstone v. Reliance Standard Life, 19-1362

Amy Silverstone sued Reliance Standard Life Insurance Company under ERISA, claiming wrongful denial of continued long‑term disability (LTD) benefits.
Both parties filed cross‑motions for summary judgment; the district court initially granted summary judgment to Silverstone, finding Reliance abused its discretion.
The district court then reconsidered, concluded Silverstone bore the burden to prove total disability, vacated its prior order, and granted summary judgment for Reliance.
The Fourth Circuit reviews district court dispositions of cross‑motions de novo and reviews ERISA administrator benefit denials for abuse of discretion when the plan grants discretion.
The Fourth Circuit affirmed, holding Reliance did not abuse its discretion in denying continued LTD benefits and adopted the district court’s reasoning.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Reliance abused its discretion in denying continued LTD benefits	Reliance’s denial was arbitrary/unreasonable	The denial was reasonable and supported by the record; Silverstone failed to prove total disability	Reliance did not abuse its discretion; denial affirmed
Who bears the burden to prove continued total disability	Silverstone contended the denial was wrongful (implicitly challenging findings)	Silverstone bears the burden to submit proof of total disability; she failed to meet it	Burden is on Silverstone; failure to prove disability supports denial
Proper standards on review of cross‑motions and ERISA decisions	Silverstone argued administrator’s decision should be overturned as unreasonable	Court should apply de novo review to summary‑judgment posture and abuse‑of‑discretion for ERISA merits	Court applied de novo to summary judgment motions and abuse‑of‑discretion to the administrator’s decision; decision was reasonable

Bostic v. Schaefer, 760 F.3d 352 (4th Cir. 2014) (de novo review of district court disposition of cross‑motions for summary judgment)
Desmond v. PNGI Charles Town Gaming, L.L.C., 630 F.3d 351 (4th Cir. 2011) (each cross‑motion examined separately under Rule 56)
Lawson v. Union Cty. Clerk of Court, 828 F.3d 239 (4th Cir. 2016) (summary judgment standard: no genuine dispute and entitlement as a matter of law)
Fortier v. Principal Life Ins. Co., 666 F.3d 231 (4th Cir. 2012) (ERISA administrator decisions reviewed for abuse of discretion when plan grants discretion)
Booth v. Wal‑Mart Stores, Inc. Assocs. Health & Welfare Plan, 201 F.3d 335 (4th Cir. 2000) (nonexhaustive factors that inform abuse‑of‑discretion review)
Griffin v. Hartford Life & Accident Ins. Co., 898 F.3d 371 (4th Cir. 2018) (administrator’s decision must result from deliberate, principled reasoning and be supported by substantial evidence)
Williams v. Metro. Life Ins. Co., 609 F.3d 622 (4th Cir. 2010) (court will not disturb a reasonable administrator decision even if it would reach a different conclusion)