The Eighth Circuit applied the Supreme Court’s MetLife v. Glenn conflicts analysis and turned the tables for a disabled participant’s decade-long quest for disability benefits in the case of Chronister v. Unum Life Insurance Company of America (posted at Plan Sponsor), holding that the insurer had abused its discretion in terminating the participant’s disability benefits. While the Eighth Circuit noted the insurer’s “history of biased claims administration” as one factor that the court must consider in determining whether there was an abuse of discretion, the court considered the insurer’s “failure to follow its own claims-handling procedures” with respect to how it dealt with the Social Security’s determination that the participant was disabled to be “most egregious.”
Specifically, the court noted the insurer’s failure to consider the SSA’s disability determination (“It appears from the denial letter that [the insurer] did not consider the SSA’s disability determination at all”) and its failure to articulate in its denial letter to the participant as to why the insurer was disregarding the SSA disability determination. The court noted that the insurer’s own claims procedures required the insurer to accord “significant weight” to the SSA’s disability determination and that any denial letter should articulate the reasoning and analysis for disregarding the determination as the claims manual required.
In the end, the court cut to the chase and bypassed a remand for further proceedings by entering judgment in the participant’s favor “given that her benefits claims have been pending for more than a decade.”
UPDATE: By the way, the CDC said last week that 1 in 5 Americans are living with at least one disability.