Robert George v. Reliance Standard Life Ins Co.
776 F.3d 349
| 5th Cir. | 2015Background
- Robert George, a former Army helicopter pilot and PHI pilot, stopped flying in 2008 due to amputation-related pain and could not use a prosthetic; he earned ~$75,495 at retirement and claimed long-term disability under PHI’s Reliance Standard Life (RSL) policy.
- The Policy defines “Totally Disabled” as inability to perform regular occupation for first 24 months, then inability to perform any occupation that provides "substantially the same earning capacity."
- The Policy contains an exclusion: monthly benefits for disability "caused by or contributed to by mental or nervous disorders" are capped at a 24-month lifetime maximum; "mental or nervous disorders" includes depression and PTSD.
- RSL denied benefits, finding George could perform sedentary work (Protective-Signal Operator, Crew Scheduler, Aircraft-Log Clerk) and that his depression/PTSD contributed to his impairment, triggering the exclusion.
- District court reviewed under abuse-of-discretion (administrator had discretionary authority) and affirmed RSL on contribution/exclusion grounds without resolving whether George satisfied the "substantially the same earning capacity" element.
- Fifth Circuit majority reversed: held RSL abused its discretion in (1) concluding George could obtain substantially the same earnings in alternative work absent supporting evidence, and (2) applying the mental-disorder exclusion because there was no record evidence that George’s physical condition alone would not have rendered him totally disabled.
Issues
| Issue | Plaintiff's Argument (George) | Defendant's Argument (RSL) | Held |
|---|---|---|---|
| Whether claimant bore the initial burden of proof and whether court may consider only reasons given in administrative record | George conceded initial burden at argument but urged focus on administrative reasons supplied to him | RSL relied on record bases it articulated in claim-denial letters | Court assumed George bore burden but limited review to reasons RSL gave during claims process (no post-hoc rationales) |
| Whether RSL reasonably found George not "Totally Disabled" after 24 months because he could perform alternative sedentary occupations | George: no evidence shows those jobs pay "substantially the same earning capacity" as his pilot salary | RSL: vocational expert identified alternative occupations; claimant must show inability to perform any occupation | Held: RSL abused its discretion — record lacks substantial evidence that alternatives would provide substantially similar earnings |
| Whether RSL reasonably applied the mental/nervous-disorder exclusion ("caused by or contributed to by") to bar benefits beyond 24 months | George: exclusion applies only if mental disorder is a but-for cause; physical limitations alone would bar him from earning substantially similar income, so exclusion doesn't apply | RSL: George’s depression/PTSD impaired his ability to hold a job and thus contributed to total disability | Held: Majority — RSL abused its discretion; no rational connection between mental-condition evidence and conclusion that mental disorder caused or contributed to total disability because physical limits alone precluded substantially similar earnings; Dissent — reasonable to apply exclusion given mental impairment evidence |
| Standard of review: scope and degree of deference to administrator | George: abuse-of-discretion applies but administrator must base denial on record evidence supporting reasons provided | RSL: discretionary grant allows deference to administrator’s determinations | Held: Abuse-of-discretion standard applies; administrator must have a rational, evidence-supported basis and cannot advance new rationales post hoc |
Key Cases Cited
- Vega v. Nat’l Life Ins. Servs., 188 F.3d 287 (5th Cir. 1999) (abuse-of-discretion standard where plan grants administrator discretionary authority)
- Holland v. Int’l Paper Co. Ret. Plan, 576 F.3d 240 (5th Cir. 2009) (standard for reviewing plan administrator determinations)
- Ellis v. Liberty Life Assurance Co. of Boston, 394 F.3d 262 (5th Cir. 2004) (administrator’s decision must be supported by substantial evidence; claimant must show administrator’s position lacks support)
- Duhon v. Texaco, Inc., 15 F.3d 1302 (5th Cir. 1994) (distinguished: plan at issue disallowed "any job" test and lacked similar-earnings requirement)
- Truitt v. Unum Life Ins. Co. of Am., 729 F.3d 497 (5th Cir. 2013) (abuse-of-discretion review: decision must have a rational connection to facts in record)