Schorsch v. Reliance Standard Life Ins. Co.

Federal 7th Circuit Court
Civil Court
Case Number: 
No. 10-3524
Decision Date: 
August 28, 2012
Federal District: 
N.D. Ill., E. Div.
Dist. Ct. did not err in granting defendant's motion for summary judgment in plaintiff's ERISA action alleging that defendant wrongfully terminated plaintiff's long-term disability benefits under plan offered by plaintiff's employer, after finding that plaintiff had failed to administratively exhaust her remedies by failing to seek internal appeal of denial prior to filing instant action, as required under Edwards, 639 F.3d 355. While record showed that defendant lost administrative record of plaintiff's claim and gave plaintiff improper impression that denial was based solely on medical records, rather than on additional factor that plaintiff was observed performing babysitting services that were in contravention to her claimed disability, plaintiff failed to show that any of defendant's missteps played role in her own failure to seek internal review of defendant's denial.