Employee Benefits

Applicant for SSI benefits based on her depression and certain physical impairments was entitled to new hearing where ALJ failed to include applicant's moderate limitation on concentration, persistence and pace in hypothetical he posed to vocational expert when expert concluded that applicant could obtain competitive employment. Ct. rejected Commissioner's argument that ALJ actually accounted for instant moderate limitations by restricting hypothetical to unskilled work since it was unclear that instant hypothetical would cause expert to eliminate positions that would pose significant barriers to someone with applicant's limitations.

Record contained sufficient evidence to support ALJ's denial of claimant's application for disability benefits after ALJ found that claimant's testimony about her pain-induced functional limitation in areas of walking and sitting was not credible. While ALJ was factually mistaken with respect to time-gap between treatments for claimant's disabilities, instant denial was supported by medical evidence contradicting claimant's allegations of disabling pain, as well as testimony of treating physicians, who described claimant's symptoms as being benign and non-debilitating.

Dist. Ct. did not err in granting plaintiff-union pension plan's motion for summary judgment in ERISA action seeking under 29 USC section 1399(c)(5)(B) interim payment consisting of entire amount of withdrawal liability from defendant-employer after defendant announced that it was preparing for its termination and liquidation. Under 1399(c)(5)(B), entire amount of withdrawal payment is immediately payable upon default, and defendant's obligation for making interim payment is not deferred even though parties are undergoing arbitration.

Dist. Ct. did not err in affirming ALJ’s denial of claimant’s application for disability insurance and disability widow’s benefits based on claimant’s fibromyalgia, depression, obesity, chronic fatigue syndrome, and high blood pressure. Claimant failed to present any medical evidence linking her chronic fatigue syndrome to unacceptable level of absenteeism, and ALJ could properly determine that claimant’s obesity, along with other impairments, did not rise to medical definition of any currently listed impairment. Ct. also rejected claimant’s contention that ALJ improperly found claimant to be incredible with respect to her claim that her pain prevented her from working.

Dist. Ct. did not err in granting defendant-plan administrator's counterclaim for equitable reformation of ERISA pension plan to correct scrivener's error in plan's calculation of benefits. Section 502(a)(3) of ERISA authorizes plan administrator to seek equitable reformation of plan, and defendant showed by clear and convincing evidence via plan's drafting history and defendant's course of conduct that plan contained drafting error in calculation formula that did not reflect plan participant's reasonable expectations of benefits.

Dist. Ct. erred in granting defendant-plan administrator's motion for summary judgment in ERISA action alleging that defendant wrongfully terminated plaintiff's long-term disability benefits even though plaintiff asserted that she could no longer work in any occupation as result of painful nerve condition in her right arm. Plaintiff need not prove her condition only through use of objective data where, as here, no definite objective test exists for plaintiff's condition, and record showed that instant denial was arbitrary where: (1) certain functional capacity evaluations (FCE) indicated that plaintiff had total disability; (2) defendant failed to explain why it found most recent FCE unreliable; (3) defendant failed to consider fact that plaintiff satisfied requirements for receiving SSI benefits; (4) record failed to support defendant's claim that plaintiff's surgeries had resolved her condition; (5) defendant relied on opinions of physicians who had never examined plaintiff; and (6) defendant repeatedly imposed new testing requirements once plaintiff had satisfied prior requirements.

Record failed to support ALJ's denial of claimant's application for Supplemental Security Income based on contention that claimant suffered from anxiety, depression and ankle pain. ALJ improperly failed to give controlling weight to opinion of claimant's treating psychiatrist, who concluded that claimant's history of episodes of decompensation were sufficient to qualify claimant's condition as listed impairment, where ALJ disregarded medical evidence supporting finding of disability and failed to note long-standing nature of psychiatrist's treatment relationship with claimant. Moreover, nothing in record supported ALJ's inference that there were ways in which claimant's condition could be treated or managed.

Dist. Ct. did not err in granting defendant-pension plan's motion for summary judgment in action alleging that instant pension plan violated ERISA by discontinuing yearly 8.5% interest credits in calculation of plaintiffs' pension benefits once plaintiffs reached age of 55. Ct. rejected plaintiffs' claim that instant interest credits formed part of employees' benefit accrual where Ct. found that employees receiving interest credits prior to age 55 did not receive more benefits that employees retiring at normal retirement age and said credits did not affect ultimate value of pension payments given to employees retiring at normal retirement age. Moreover, instant plan satisfied ERISA requirement that all employees receive actuarial equivalent of pension benefits even if employees take lump-sum payments for retiring early.