Corey v. Sedgwick Claims Management Services, Inc.
858 F.3d 1024
| 6th Cir. | 2017Background
- Plaintiff Bruce Corey, an Eaton machine operator, suffers chronic cluster headaches and applied for short-term disability benefits in 2014 after missing work.
- Eaton’s disability plan grants the Administrator discretionary authority and requires “objective findings” to substantiate disability, explicitly listing “medications and/or treatment plan” as examples.
- Corey’s treating physicians documented severe, incapacitating cluster-headache episodes and a treatment regimen including prednisone, Imitrex injections, supplemental oxygen, lamotrigine, occipital nerve block, and planned occipital nerve stimulation.
- The Administrator initially approved benefits through May 7, 2014, then denied benefits after that date for lack of objective findings; independent reviewers concluded cluster headaches produce no objective neurological abnormalities.
- Denial letters quoted plan language but did not explain why Corey’s documented medications and treatment plan failed to satisfy the plan’s objective‑findings requirement.
- Corey sued under ERISA § 502(a)(1)(B); the district court upheld the denial, and the Sixth Circuit reviewed under the arbitrary-and-capricious standard because the plan vested discretion in the Administrator.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether medications/treatment-plan entries listed as “objective findings” in the plan can satisfy the plan’s objective‑findings requirement | Corey: plan expressly lists “medications and/or treatment plan”; his documented regimen therefore meets objective‑findings requirement | Administrator: requires either (a) medication side effects causing disability, or (b) medication/treatment that objectively confirms inability to work; Corey’s records don’t meet that higher showing | Held for Corey: plain plan text includes medications/treatment as objective findings; Administrator’s extra requirements lack textual support |
| Whether Administrator provided a reasoned, principled explanation for denying benefits | Corey: denial was conclusory and failed to address how his treatment records fit the plan’s definition | Administrator: relied on independent reviewers and discretion to conclude no objective evidence of disability | Held: Administrator’s decision arbitrary and capricious because it offered no explanation applying plan’s definition and relied on post‑hoc rationales |
| Whether cited precedent (Scott, McGruder) justifies Administrator’s approach | Corey: precedents are inapposite because those cases turned on alleged medication side‑effects, not underlying condition | Administrator: relied on those cases to support requiring corroboration beyond prescription/treatment | Held: those cases unpersuasive here because Corey asserts disability from the underlying condition, not medication side effects |
| Remedy: What remand is appropriate | Corey: remand for a full and fair review applying the plan’s plain language | Administrator: (implicit) uphold denial | Held: vacated district court judgment and remanded to district court with instruction to remand to Administrator for full and fair review consistent with opinion |
Key Cases Cited
- Spangler v. Lockheed Martin Energy Sys., 313 F.3d 356 (6th Cir. 2002) (arbitrary-and-capricious standard where plan grants discretion)
- Glenn v. MetLife, 461 F.3d 660 (6th Cir. 2006) (upholding administrator’s decision if based on deliberate, principled reasoning and supported by substantial evidence)
- Shaw v. AT&T Umbrella Benefit Plan No. 1, 795 F.3d 538 (6th Cir. 2015) (review limited to evidence available to administrator at time of decision)
- McClain v. Eaton Corp. Disability Plan, 740 F.3d 1059 (6th Cir. 2014) (procedural limits on review and reliance on administrative record)
- Univ. Hosps. of Cleveland v. Emerson Elec. Co., 202 F.3d 839 (6th Cir. 2000) (rejecting post‑hoc rationalizations and requiring actual administrative rationale)