Dragus v. Reliance Standard Life Ins. Co.

Dist. Ct. did not err in granting defendant-insurance company’s motion for summary judgment in plaintiff-insured’s ERISA action alleging that defendant wrongfully denied his application for long-term disability benefits based on plaintiff’s claim of severe neck pain. Instant group insurance policy conferred discretionary authority on defendant to determine eligibility for such benefits, such that defendant was entitled to arbitrary and capricious standard of review, even though defendant failed to render timely decision under 29 CFR section 2560.503-1(f)(3). Moreover, plaintiff failed to show that denial of benefits was either arbitrary or capricious, where defendant relied on medical opinions from four independent individuals, who took into consideration plaintiff’s medical records, complaints and medication regiment in finding that plaintiff was not eligible for said benefits and whose compensation did not depend on outcome of their opinions. Fact that plaintiff received fully favorable decision on his application for SSDI benefits did not require different result under instant standard of review.