Following a denial of long-term disability benefits by a plan’s claims administrator, which was upheld by a United States District Court, the claimant appealed to the Court of Appeals for the District of Columbia Circuit. The claimant argued that the district court improperly deferred to the claims administrator’s determination, rather than reviewing afresh her claim for disability benefits. In support of this argument, the claimant asserted that only the disability policy document was relevant in determining whether the claims administrator possessed discretionary authority to determine eligibility for benefits or to construe the terms of the plan. The claims administrator asserted that all policy documents should be considered together.
The D.C. Circuit agreed with the claims administrator, holding that the district court correctly ruled that all plan documents should be analyzed in determining whether an administrator or fiduciary possesses discretionary authority to determine eligibility for benefits or to construe the terms of the plan. Having determined that all plan documents are relevant in determining the proper standard of review to be applied by courts to an administrator or fiduciary’s decision to deny a claim for benefits, the D.C. Circuit held that the totality of plan documents conferred discretionary authority upon the claims administrator to determine benefits eligibility and to interpret plan terms.
The D.C. Circuit then applied the “reasonableness” standard, applicable when an administrator possesses discretionary authority, to hold that the claims administrator acted reasonably in crediting its own doctor’s opinion over that of the claimant’s doctor when denying the disability claim. (Pettaway v. Teachers Ins. & Annuity Assoc., D.C. Circuit 2011)