Dorris v. Unum Life Ins. Co.

Dist. Ct. did not err in entering judgment in favor of defendant-insurance company in plaintiff-insured’s ERISA action alleging that defendant wrongfully terminated her disability benefits under defendant’s disability insurance policy, after defendant claimed that plaintiff could perform duties of her regular occupation as president of company. Although Dist. Ct. agreed with plaintiff that she could not perform duties of her regular occupation, plaintiff failed to present any evidence to meet her burden of establishing that she could not work at other occupations so as to support her claim for disability benefits. Fact that plaintiff had previously obtained Social Security disability benefits did not require different result, where: (1) Social Security disability determination was only one factor for ERISA benefits determination; (2) said determination occurred eight years prior to defendant’s termination of benefits; and (3) instant lack of evidence as to whether plaintiff could perform other occupations precluded finding that Dist. Ct. “clearly erred” in finding that plaintiff had failed in her burden that she could not perform other occupations. Also, Dist. Ct. did not err in denying plaintiff’s motion to reopen discovery, where said motion was filed after Dist. Ct. had rendered instant judgment.