Sharon Wade v. Aetna Life Insurance Company
684 F.3d 1360
8th Cir.2012Background
- Wade's LTD benefits under an employer welfare plan were terminated by Aetna Life Insurance, the plan administrator.
- Wade filed suit under ERISA seeking review of Aetna's termination decision, district court granted summary judgment for Aetna.
- Wade contends the court applied the wrong standard of review and failed to weight SSA benefits; also argues substantial evidence does not support termination.
- The plan grants Aetna discretionary authority to determine eligibility for benefits.
- The court ultimately applied abuse-of-discretion review and held substantial evidence supported termination; SSA determination was not binding.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What is the proper standard of review? | Wade seeks de novo review due to alleged procedural irregularities. | Abuse-of-discretion review applies because the plan grants discretion. | Abuse-of-discretion review governs. |
| Should SSA disability findings be controlling? | SSA grant should weigh heavily, possibly control. | SSA determinations are not binding in ERISA plans. | SSA findings are not binding on the plan administrator. |
| Did procedural irregularities warrant de novo review? | Aetna's delayed production of plan documents and later submission constitute irregularities warranting de novo review. | Irregularities occurred post-decision and did not affect the substantive decision. | No de novo review; irregularities did not affect the decision. |
| Did substantial evidence support termination of benefits? | SSA benefits and prior record support Wade's disability. | New information and independent evaluations supported termination. | Yes; substantial evidence supported termination. |
Key Cases Cited
- Farfalla v. Mut. of Omaha Ins. Co., 324 F.3d 971 (8th Cir. 2003) (SSA disability determinations not binding on ERISA plan administrators)
- Jackson v. Metro. Life Ins. Co., 303 F.3d 884 (8th Cir. 2002) (SSA determinations not controlling in ERISA contexts)
- Woo v. Deluxe Corp., 144 F.3d 1157 (8th Cir. 1998) (procedural irregularities may affect standard of review under Woo sliding scale)
- Menz v. Proctor & Gamble Health Care Plan, 520 F.3d 865 (8th Cir. 2008) (irregularities must connect to the substantive decision to alter review level)
- Metro. Life Ins. Co. v. Glenn, 554 U.S. 105 (U.S. 2008) (rejected Woo sliding-scale as post-Glenn; procedural issues addressed separately)