Sharon WADE, Appellant, v. AETNA LIFE INSURANCE COMPANY, Appellee.
No. 11-3295
United States Court of Appeals, Eighth Circuit.
July 24, 2012
684 F.3d 1360
Sharon WADE, Appellant, v. AETNA LIFE INSURANCE COMPANY, Appellee.
No. 11-3295.
United States Court of Appeals, Eighth Circuit.
Submitted: April 18, 2012.
Filed: July 24, 2012.
Deborah A. Arbogast, St. Louis, MO, Sophie Woodworth, Kansas City, MO, for appellant.
Patrick J. Kenny, Darryl M. Chatman, St. Louis, MO, for appellеe.
Before RILEY, Chief Judge, MURPHY and MELLOY, Circuit Judges.
Aetna Life Insurance Company, as the plan administrator, detеrmined Sharon Wade was no longer disabled and stopped paying long-term disability benefits from Wade‘s fоrmer employer‘s welfare benefit plan. Wade sought judicial review of Aetna‘s decision by filing a сivil action under the Employee Retirement Income Security Act of 1974 (ERISA),
On appeal, Wade requests that we “order the district court to reinstate [Wade‘s] benefits” and award attorney fees pursuant to
The district court reviewed Aetna‘s termination of Wade‘s benefits under an abuse of discretion standard because the district court correctly decided the operative plan granted Aetna discretionary authority to determine whether Wade was entitled to benefits. See id. (stating an abuse of discretion standard applies “when an ERISA plan grants the administratоr discretion to construe the plan and to determine benefits eligibility” (quoting Jessup v. Alcoa, Inc., 481 F.3d 1004, 1006 (8th Cir.2007)) (internal marks omitted)).
Wade contends a de nоvo standard of review should apply because “Aetna committed serious procedural irregularities,” such as (1) failing to provide Wade‘s attorney the operative plan documents for over two years, and (2) later introducing the correct documents to the district court. See Woo v. Deluxe Corp., 144 F.3d 1157, 1160 (8th Cir.1998) (explаining a less deferential standard of review is appropriate where there is “material, prоbative evidence demonstrating that (1) a serious procedural irregularity existed, which (2) caused а serious breach of the plan administrator‘s fiduciary duty“), abrogated in part by Metro. Life Ins. Co. v. Glenn, 554 U.S. 105, 128 S.Ct. 2343, 171 L.Ed.2d 299 (2008). We disagree.
In rejecting Wade‘s argumеnt, the district court, without excusing Aetna‘s mistakes, recognized that the procedural irregularities at issuе “occurred long after the claims decision to terminate [Wade‘s long-term disability] benefits was made, and after the appeal of that decision was concluded.” The district court reasoned Wade had “not shown any facts to indicate that Aetna‘s subsequent procedural errors could hаve had any effect on either the claims decision or the appeal process.” The district court was correct. Assuming Woo still applies,2 the de novo standard Wade suggests is not warranted in situations such as this, wherе the procedural irregularities had no “connection to the substantive decision reached.” Menz v. Procter & Gamble Health Care Plan, 520 F.3d 865, 869 (8th Cir.2008) (quoting Buttram v. Cent. States, Se. & Sw. Areas Health & Welfare Fund, 76 F.3d 896, 901 (8th Cir.1996)) (internal quotation marks omitted).
We also disagree with Wade‘s contention “Aetna abused its discretion by ignoring and failing to place any weight on” the SSA‘s award of long-term disability benefits to Wade. “[A]n ERISA plan administrator or fiduciary generally is nоt bound by an SSA determination that a plan participant is disabled.” Farfalla v. Mut. of Omaha Ins. Co., 324 F.3d 971, 975 (8th Cir.2003) (quoting Jackson v. Metro. Life Ins. Co., 303 F.3d 884, 889 (8th Cir.2002)) (internal marks omitted). Aetna terminatеd Wade‘s benefits nearly five years after the SSA evaluated and approved Wade‘s benefits. Aеtna‘s decision was based on new information the SSA
After careful review of the record, we agree with the district court “that substantial evidence supports Aetna‘s decision to terminate [Wade‘s] long-tеrm disability benefits.” We therefore affirm the judgment of the district court for the reasons stated in its thorough and wеll-reasoned opinion. See 8th Cir. R. 47B.