Nicholas Brooks v. Ryder System, Incorporated
686 F. App'x 291
| 5th Cir. | 2017Background
- Nicholas D. Brooks, an employee covered by the Ryder Texas Occupational Injury Benefit Plan, injured his thumb and lower back in a July 2013 workplace fall.
- Ryder System, Inc. (RSI) is the plan administrator under ERISA.
- RSI denied Brooks’s medical claim: it concluded the thumb injury was a degenerative exclusion under the Plan and noted Brooks missed two required appointments.
- RSI denied wage-replacement beyond termination, finding Brooks received full pay from injury date until his termination, after which benefits ceased.
- Brooks sued under ERISA alleging improper denial of benefits and failure to timely provide claim documents; the district court granted RSI summary judgment and dismissed with prejudice.
- On appeal, Brooks argued RSI abused its discretion in denying benefits and violated 29 U.S.C. § 1132(c)(1) by untimely providing the administrative record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RSI abused its discretion denying medical benefits (thumb) | Brooks: thumb injury covered; denial improper | RSI: thumb was a degenerative exclusion and claimant missed required appointments | Court: No abuse of discretion; denial supported by record |
| Whether RSI abused its discretion denying wage-replacement | Brooks: wrongful cutoff of wage benefits | RSI: Brooks received full pay until termination so benefits properly ceased at termination | Court: No abuse of discretion; record supports RSI’s determination |
| Whether RSI violated ERISA by failing to timely provide administrative record (penalties under §1132(c)(1)) | Brooks: RSI failed timely to provide claim documents; seek penalties | RSI: complied sufficiently; no basis for penalties | Court: No genuine issue of material fact showing entitlement to penalties; summary judgment for RSI affirmed |
| Whether summary judgment was appropriate under abuse-of-discretion standard | Brooks: disputes of fact preclude summary judgment | RSI: record supports determination; plan grants discretionary authority | Court: Abuse-of-discretion (arbitrary-and-capricious) standard applies; no material factual dispute; summary judgment proper |
Key Cases Cited
- Pub. Citizen Inc. v. La. Att’y Disciplinary Bd., 632 F.3d 212 (5th Cir.) (standard of review for appellate summary judgment review)
- Cooper v. Hewlett–Packard Co., 592 F.3d 645 (5th Cir.) (ERISA cases governed by standard summary judgment rules)
- Metro. Life Ins. Co. v. Glenn, 554 U.S. 105 (U.S.) (plan administrator’s discretionary authority triggers abuse-of-discretion review)
- Ellis v. Liberty Life Assur. Co. of Bos., 394 F.3d 262 (5th Cir.) (summary judgment and substantial-evidence standard in ERISA benefits cases)