Cerentano v. UMWA Health and Retirement Funds

Dist. Ct. erred in granting defendant-pension plan’s motion for summary judgment in plaintiff-coal minor’s ERISA action alleging that defendant wrongfully denied his application for disability benefits under said plan, after defendant found that there was no causal link between plaintiff’s mine injuries and plaintiff’s award of Social Security disability benefits that, according to defendant, were based on physical and mental conditions that arose from car accident that occurred after plaintiff had left mine. Defendant, in denying instant application, failed to assess whether plaintiff’s mine injuries were “a causal link” in Social Security’s ALJ decision to award Social Security disability benefits, and record showed that plaintiff’s elbow injury from mine could have comprised “a causal link” in ALJ decision. Fact that elbow injury was not itself disabling did not preclude plaintiff from obtaining benefits under plan.