Employee Benefits

Record contained sufficient evidence to support ALJ’s denial of claimant’s application for Social Security disability benefits based on claimant’s back condition where denial was based on existence of 7,500 light duty jobs that were available to individual with claimant’s limitations. ALJ could rely on opinions of two physicians that claimant’s back condition did not meet any listed impairment. Moreover, ALJ provided adequate explanation for rejecting opinion of one physician who supported claimant’s application where said physician treated claimant only infrequently and gave claimant only limited number of tests. Also, ALJ could discount claimant’s report of pain where record showed that claimant regularly performed household activities without use of pain medication.

Dist. Ct. erred in granting defendant-employer’s motion for summary judgment in ERISA action by plaintiff-employee alleging that he was terminated in retaliation for making verbal complaints that defendant had failed to deposit money withheld from his paycheck into his retirement account. While Dist. Ct. found that plaintiff’s verbal complaints were not covered under anti-retaliation provisions of section 510(a) of ERISA because they were not part of “inquiry” associated with formal proceeding, Ct. of Appeals found that section 510(a) covered bona fide employee grievances regardless of whether employer had solicited information regarding employee’s grievance, and that instant complaints about funding plaintiff’s retirement account qualified as “inquiry” where defendant had allegedly responded to said complaints by taking adverse action.

Record failed to support ALJ's denial of claimant's application for Social Security disability benefits based on her anxiety, depression, fibromyalgia and carpel tunnel syndrome conditions. Claimant presented new evidence supporting her claim that she had legitimate fibromyalgia condition, and Social Security Administration Appeals Council erred in ignoring said evidence when rejecting claimant's appeal. Moreover, new hearing was required since ALJ failed to analyze medical evidence from treating doctor that supported claimant's disability claim and failed to consider evidence indicating that claimant could function only inconsistently in normal work environment.

Dist. Ct. did not err in granting defendant's motion for summary judgment in plaintiff's ERISA action alleging that defendant wrongfully terminated plaintiff's long-term disability benefits under plan offered by plaintiff's employer, after finding that plaintiff had failed to administratively exhaust her remedies by failing to seek internal appeal of denial prior to filing instant action, as required under Edwards, 639 F.3d 355. While record showed that defendant lost administrative record of plaintiff's claim and gave plaintiff improper impression that denial was based solely on medical records, rather than on additional factor that plaintiff was observed performing babysitting services that were in contravention to her claimed disability, plaintiff failed to show that any of defendant's missteps played role in her own failure to seek internal review of defendant's denial.

Dist. Ct. did not err in confirming arbitrator's decision that reduced by $1.093 million defendant-employer's withdrawal liability after defendant notified plaintiff-pension plan that it was no longer participating in said plan. Arbitrator could properly reduce defendant's withdrawal liability where: (1) said liability is based in part on applicable interest rate determined by actuary; (2) ERISA requires that computation of withdrawal liability be based on best estimate of actuarial assumptions; and (3) plaintiff had previously directed actuary to use rate other than actuary's best estimate of correct interest rate, which in turn, increased defendant's withdrawal liability by $1.093 million from amount it would have owed had actuary's best estimate of interest rate been used throughout applicable period.

Dist. Ct. did not err in granting defendant-plan's motion for summary judgment in ERISA action alleging that defendant improperly denied coverage under health-care benefits plan for plaintiff's stay in nursing home. Terms of plan precluded coverage for treatment that did not require skilled nursing services and was otherwise designed to assist patient with simple activities of daily living. Moreover, defendant's decision to deny plaintiff's claim was not arbitrary or capricious where three different independent physicians determined that plaintiff had received only custodial, as opposed to skilled care, for her heart failure, diabetes and renal insufficiency conditions. Fact that plaintiff received assistance with her medications and with her diabetes testing and monitoring did not require finding that plaintiff had received skilled nursing services.