Newsom v. Reliance Stnrd Life Ins, 26 F.4th 329

Lereta, LLC offered STD and LTD benefits under an ERISA plan insured and administered by Reliance Standard; the LTD policy defined “full‑time” as a minimum of 30 hours in a “regular work week” but did not define “regular work week.”
Newsom, a long‑time software architect with chronic medical conditions, was scheduled for 32 hours/week through mid‑October 2017, then scheduled at 28 hours/week beginning around October 23, 2017, and stopped working entirely on January 30, 2018.
Reliance initially denied STD benefits as Newsom allegedly was not full‑time, but on appeal accepted a date of disability in late October 2017 and paid the 26‑week STD benefit. Reliance denied LTD benefits, finding Newsom ineligible because he had not worked 30+ hours in the weeks before January 31, 2018.
Newsom sued under ERISA § 1132(a)(1)(B). The district court construed “regular work week” to mean the employer’s scheduled work week, held Newsom full‑time and that his disability date was October 23, 2017, and awarded LTD benefits and attorney’s fees.
The Fifth Circuit affirmed the district court’s interpretations of eligibility and disability date, but vacated the district court’s award of LTD benefits (and attorney’s fees) and remanded so the administrator can decide, on the merits, whether Newsom is disabled and the correct benefit amount.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper meaning of “regular work week” / “full‑time” eligibility	“Regular work week” means the employer’s scheduled or normal work week; scheduled 32‑hr weeks make Newsom full‑time	Means hours actually worked each week; Newsom’s actual weeks under 30 hrs made him ineligible	Term is ambiguous; construed for insured as scheduled work week (affirmed)
Proper date of disability	Date disability began is week of Oct 16/23, 2017 when schedule cut to 28 hrs	Date of disability is Jan 31, 2018 when Newsom stopped working entirely	District court’s factual finding of Oct 23, 2017 not clearly erroneous (affirmed)
Whether district court should decide entitlement/award benefits or remand	No remand; court should decide de novo and award benefits now	Remand needed because administrator never reached merits after denying eligibility	Remand required: eligibility and date addressed, but administrator must decide merits and benefit amount (vacated award)
Attorney’s fees award	Fees proper after district court victory	Fees premature if benefits entitlement remanded	Fees order vacated and to be reconsidered after remand

Miller v. Reliance Standard Life Ins. Co., 999 F.3d 280 (5th Cir. 2021) (construed same Reliance policy; held “regular work week” ambiguous and applied contra proferentem in insured’s favor)
Ariana M. v. Humana Health Plan of Texas, Inc., 884 F.3d 246 (5th Cir. 2018) (discusses standard of review for administrators’ factual findings in ERISA cases)
Vega v. National Life Insurance Services, Inc., 188 F.3d 287 (5th Cir. 1999) (generally discourages remanding to administrator to make a fuller record; limited where only discrete issue existed)
Schadler v. Anthem Life Insurance Co., 147 F.3d 388 (5th Cir. 1998) (instructed remand for administrator to develop full factual record when administrator initially denied coverage)
Pakovich v. Broadspire, 535 F.3d 601 (7th Cir. 2008) (persuasive authority that remand is appropriate where plan determined eligibility but did not decide the merits of disability)
Wallace v. Oakwood Healthcare, Inc., 954 F.3d 879 (6th Cir. 2020) (construed similar Reliance policy language and found ambiguity)
Metropolitan Life Ins. Co. v. Glenn, 554 U.S. 105 (2008) (addressed insurer conflict of interest and deference issues in ERISA benefit denials)
Katherine P. v. Humana Health Plan, Inc., 959 F.3d 206 (5th Cir. 2020) (confirms that judicial review in ERISA is limited to the administrative record)