Matthew v. Unum Life Insurance Co. of America, 639 F.3d 857

Matthew, a urologic surgeon, sought disability benefits under Unum's policy after ceasing certain procedures due to a degenerative ankle condition.
The policy uses a residual-disability framework with a formula referencing 'loss of net income,' prior net income indexed to CPI-U, and a 20% threshold for residual benefits.
Unum delayed and conditioned payment while requesting financial records; Matthew provided most records but resisted supplying tax returns for several years.
In 2008, Unum determined total disability began July 12, 2005 and disputed residual benefits prior to that date; Matthew sued in 2008 seeking total or residual benefits and Unum sought overpayment recovery.
A jury awarded Matthew residual benefits for October 1, 1996 through December 1, 2004 and total disability from December 1, 2004 onward, with a special verdict amount reflecting overpayment confused by closing arguments.
The district court corrected the verdict amount, awarded prejudgment interest, and denied post-trial motions; Unum appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the special verdict correction was proper	Matthew asserts Rule 59(e) allows correction of manifest errors in the verdict.	Unum contends the correction improperly altered the jury's damages calculation.	District court did not abuse discretion; corrected face-of-verdict mistake.
Whether prejudgment interest was appropriate under Minnesota law	Matthew argues prejudgment interest should be awarded as the damages were readily ascertainable.	Unum contends damages were not readily ascertainable due to contingencies and ongoing proof obligations.	District court erred; prejudgment interest under Minnesota common law not appropriate.
Whether the residual-disability claim was time-barred by the limitations period	Matthew contends continuing-loss provisions prevent running of the three-year limit since disability persisted.	Unum argues continuous lack of total disability only; the period should have begun to run.	Claim not barred; continuing-disability provision applies to residual as well as total disability; timely.
Whether post-trial rulings on judgments, new trial, and mistrial were correct	Matthew contends post-trial rulings supported the verdict and damages.	Unum argues for JMOL, new trial, or mistrial due to evidentiary issues and jury conduct.	Rulings affirmed except for prejudgment-interest reversal; invited-error doctrine precludes reversal on some submissions.

United States v. Metro. St. Louis Sewer Dist., 440 F.3d 930 (8th Cir. 2006) (Rule 59(e) standard for correcting judgments)
SFH, Inc. v. Millard Refrigerated Servs., Inc., 339 F.3d 738 (8th Cir. 2003) (abuse-of-discretion standard for Rule 59(e))
Innovative Home Health Care, Inc. v. P.T.-O.T. Assocs. of the Black Hills, 141 F.3d 1284 (8th Cir. 1998) (standard for assessing Rule 59(e) corrections)
Kurka v. Iowa Cnty., Iowa, 628 F.3d 953 (8th Cir. 2010) (abuse-of-discretion in Rule 59(e) context)
Ventura v. Titan Sports, Inc., 65 F.3d 725 (8th Cir. 1995) (readily ascertainable damages; prejudgment interest analysis)
Nw. Airlines, Inc. v. Flight Trails, 3 F.3d 292 (8th Cir. 1993) (readiness of damage computation; precendents on prejudgment interest)
Unique Sys., Inc. v. Zotos Int'l, Inc., 622 F.2d 373 (8th Cir. 1980) (damages not readily ascertainable; contingencies)
Ryan v. ITT Life Ins. Corp., 450 N.W.2d 126 (Minn. 1990) (continuing-disability limitations interpretation)
Laidlaw v. Commercial Ins. Co. of Newark, 255 N.W.2d 807 (Minn. 1977) (total disability limitations period start)
Weyrauch v. Cigna Life Ins. Co. of N.Y., 416 F.3d 717 (8th Cir. 2005) (continuing-disability limitations; applicability to claims)
Potter v. Hartzell Propeller, Inc., 189 N.W.2d 499 (Minn. 1971) (readily ascertainable damages; prejudgment-interest standard)