Fessenden v. Reliance Standard Life Ins. Co.

In ERISA action alleging that defendant-plan administrator improperly denied plaintiff-beneficiary’s claim for work-related long-term disability benefits through former employer’s benefits plan, Dist Ct. erred, when upholding instant denial, by applying arbitrary and capricious standard of review, where record showed that defendant had failed to issue decision on plaintiff’s internal appeal of said denial within deadline mandated by ERISA regulations. Ct. rejected defendant’s claim that use of arbitrary and capricious standard was appropriate, because it had substantially complied with ERISA regulations by issuing denial only eight days after said deadline, and further found that doctrine of substantial compliance does not apply to ERISA’s regulatory deadlines. As such, remand was required for Dist. Ct.’s determination as to whether instant denial of benefits was appropriate under de novo standard of review.