Carrow v. Standard Insurance, 664 F.3d 1254

Carrow, a Jager Industries employee, was eligible for long-term disability benefits under the Plan administered by Standard.
The Plan defines disability as own occupation for 24 months, then any occupation reasonably fitted by education, training, and experience, with Standard retaining discretionary interpretation power.
Carrow developed avascular necrosis and underwent hip surgery in 2005, receiving STD then LTD benefits through mid-2006.
After a 2006 hip replacement and later knee/spine issues, Carrow returned to work briefly in March–June 2006 but remained disabled due to ongoing pain.
Standard relied on both treating and consulting physicians, including Dr. Mullen and Dr. Carlson, to evaluate Carrow’s ability to work and ultimately denied LTD on December 12, 2007.
Carrow appeals the denial, arguing Standard abused its discretion in determining an inability to perform any occupations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Plan administrator abused discretion in any-occupation denial.	Carrow argues conflict of interest and improper weighting of evidence.	Standard contends its determinations were supported by substantial evidence and credible medical reviews.	No abuse of discretion; substantial evidence supports denial.
Whether consulting physicians' reports can carry more weight than treating physicians.	Carrow asserts treating doctors should be preferred for disability determinations.	Standard may rely on non-examining reports and compare credibility among sources.	Plan acted within discretion by considering consulting opinions alongside treating physicians.
Whether SSA disability findings bind ERISA plan decisions.	SSA findings should be controlling if consistent with plan goals.	SSA findings are not binding on ERISA plan determinations.	SSA findings are not controlling; plan properly independent.
Whether there was any inconsistency in Standard's handling of Dr. Mullen's disabling assessments.	Dr. Mullen repeatedly asserted total disability with broad limitations.	Standard sought corroboration from other physicians and evaluated credibility.	No inconsistency; Standard conducted inquiries and weighed multiple sources.

Weidner v. Federal Express Corp., 492 F.3d 925 (8th Cir. 2007) (administrative deference to consultant reports over treating physicians)
Rutledge v. Liberty Life Assurance Co. of Boston, 481 F.3d 655 (8th Cir. 2007) (credibility and comparative evaluation of medical reports in denial of benefits)
Manning v. Am. Republic Ins. Co., 604 F.3d 1030 (8th Cir. 2010) (practice of reviewing ERISA plan decisions under abuse-of-discretion standard with conflict consideration)
Jones v. ReliaStar Life Ins. Co., 615 F.3d 941 (8th Cir. 2010) (conflicts of interest weight in abuse-of-discretion review)