GAVIN v. EATON AEROQUIP INC SHORT TERM DISABILITY PLAN
2:23-cv-00433
E.D. Pa.May 22, 2025Background
- Troy Gavin suffered a stroke shortly after starting employment at Eaton Aeroquip, LLC, and was approved for short-term disability benefits through Eaton's ERISA-governed plan.
- Gavin's benefits were eventually terminated by Sedgwick, the plan administrator's delegate, after August 9, 2021, citing insufficient objective medical evidence.
- Gavin appealed the denial, underwent an independent medical examination (IME), which found he could return to work about 90 days after his stroke with certain restrictions.
- Gavin filed suit under ERISA, arguing the denial of benefits was arbitrary and capricious.
- The case comes before the court on Gavin’s motion for summary judgment, contesting the adequacy of the administrative decision-making process.
- The court must determine if there are genuine disputes of material fact that preclude summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the administrator identify and consider Gavin’s actual job duties? | Admin did not adequately identify occupation or duties. | Job title and duties were listed and considered. | Factual dispute; not resolved on summary judgment. |
| Adequacy of medical records reviewed | Denial based on lack of objective medical evidence, records were not sought by Sedgwick. | Examiner had sufficient records to make a decision. | Factual dispute; issue for fact finder. |
| Reasonableness of reliance on IME | IME was conducted too late; ignored key evidence. | IME reasonable, relied on available evidence, timing not unreasonable. | Factual dispute; issue for fact finder. |
| Standard for summary judgment | No genuine factual dispute; entitled to judgment as matter of law. | Disputes of material fact remain for trial. | Summary judgment denied; factual disputes exist. |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (1989) (establishing the standard of review for ERISA benefit denials)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (standard for summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment procedure and burden)
- Miller v. American Airlines, Inc., 632 F.3d 837 (3d Cir. 2011) (scope of review for ERISA administrator’s decisions)