Rodney Waldoch v. Medtronic, Inc.
757 F.3d 822
8th Cir.2014Background
- Waldoch sued Medtronic for improper denial of long-term disability benefits under ERISA and district court granted summary judgment for Medtronic.
- Plan is self-funded, self-administered; Hartford evaluated claims but Medtronic retained final authority.
- Disability definitions split into ‘own occupation’ and ‘any occupation’ LTD benefits.
- Hartford operated as claims administrator; Medtronic could accept or reject Hartford’s recommendations.
- Administrative record showed Hartford’s EAR and multiple physician reviews; SSA disability decision cited as non-controlling.
- Medtronic ultimately denied Waldoch’s ‘any occupation’ LTD claim after a multi-step review ending in 2011.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the plan’s discretionary authority triggers abuse-of-discretion review | Waldoch argues irregularities undermine the standard | Medtronic contends discretion applies and procedures were adequate | Discretionary review applies; no procedural irregularity suffices |
| Whether district court improperly admitted post-hoc evidence to aid standard of review | Waldoch seeks strike on supplemental record | Medtronic argues evidence clarifies process for standard | District court did not abuse discretion in admitting supplemental evidence for standard-of-review purposes |
| Whether procedural irregularities altered the applicable standard of review | Waldoch asserts serious irregularities changing review | Medtronic argues irregularities not serious enough to alter review | Procedural irregularities insufficient to alter abuse-of-discretion standard |
| Whether Medtronic abused its discretion in denying ‘any occupation’ LTD | Waldoch claims evidence showed cognitive/behavioral impairment from glucose variability | Medtronic reasonably credited evidence showing lack of objective impairment | No abuse; decision supported by substantial evidence under abuse-of-discretion standard |
| Whether SSA findings should control ERISA LTD decision | SSA ruling should control | SSA not binding on ERISA plan decisions | SSA findings not binding; properly weighed as non-controlling evidence |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (Supreme Court 1989) (establishes abuse-of-discretion standard when plan grants discretion)
- McKeehan v. Cigna Life Insurance Co., 344 F.3d 789 (8th Cir. 2003) (limits deference where discretionary authority not shown or records inadequate)
- King v. Hartford Life Ins. Co., 414 F.3d 994 (8th Cir. 2005) (en banc; defines standard for abuse-of-discretion review with discretionary plan language)
- Midgett v. Washington Grp Int’l Long Term Disability Plan, 561 F.3d 887 (8th Cir. 2009) (requires substantial evidence; deferential review intact)
- Murphy v. Deloitte & Touche Grp. Ins. Plan, 619 F.3d 1151 (10th Cir. 2010) (illustrates standard for ERISA review in context of plan processing)