Dist. Ct. did not err in granting defendant-pension fund’s motion for summary judgment in plaintiff-plan beneficiary’s action under ERISA, alleging that defendant arbitrarily denied his application for disability benefits, where it unreasonably found that he had failed to causally connect his disability to any on-the-job injury. Relevant plan language required plaintiff to show that his disability was result of accident sustained while on job, and although plaintiff supplied Social Security award letter, his own statement linking his disability to injuries sustained to his knee and shoulder, as well as his workers compensation record, and doctor’s notes, none of these documents established requisite link between his disability and any on-the-job injury. As such, defendant’s denial was not arbitrary, especially where defendant referred matter to independent medical reviewer, who also found no clear connection tying plaintiff’s disability to any workplace injury. Moreover, plan administrator’s denial was entitled to deference, where plan language conferred discretion on administrator.
Federal 7th Circuit Court
Civil Court
ERISA