Raybourne v. Cigna Life Ins. Co. of New York

Federal 7th Circuit Court
Civil Court
Citation
Case Number: 
Nos. 11-1295 & 11-1427 Cons.
Decision Date: 
November 21, 2012
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed
Dist. Ct. did not err in entering judgment in favor of plaintiff in ERISA action alleging that defendant-insurance company wrongfully terminated plaintiff’s long-term insurance benefits even though Social Security Administration (SSA) had found that plaintiff was disabled under SSA standards. Record showed that defendant operated under conflict of interest where it both insured and administered instant long-term disability plan, and any variation in disability standards between SSA and plan was too slight to justify different results. Moreover, defendant failed to account for plaintiff’s four surgeries and his continuous need for narcotic drugs when relying on report from non-treating physician to deny benefits. Defendant also failed to explain why it supported plaintiff’s successful disability claim before SSA in order to recoup benefits already paid to plaintiff and then denied him any future payments under plan.