ERISA Long Term Disability Case Citations and references

DISCLAIMER: Please note that every case is different and these verdicts and settlements, while accurate, do not represent what we may obtain for you in your case.

Is Summary Judgment the Correct Procedural Vehcle for Deciding Cases?

Several Courts have debated whether "summary judgment" is the correct procedural choice for deciding ERISA disabiliity cases.

It is necessary to confront and decide whether a Section 1132(a)(1)(B) claim which involves disputed facts should be disposed of under Rule 52 or Rule 56. The Sixth Circuit noted in Wilkins v. Baptist Healthcare Systems, Inc., 150 F.3d 609 (6th Cir. 1998) that these claims may typically be resolved in one of two ways:
1. By utilizing the summary judgment procedure set forth in Rule 56, or

2. By conducting a bench trial on the merits, making findings of fact and conclusions of law pursuant to Rule 52.

The Sixth Circuit went on to conclude, however, that neither standard is appropriately applied to claims brought under Section 1132(a)(1)(B). It concluded that a bench trial is inappropriate because it would "inevitably lead to the introduction of testimonial and/or other evidence that the administrator had no opportunity to consider." Id. at 618. The Wilkins court found similar problems with the Rule 56 summary judgment standard. Specifically, because it had concluded that a Section 1132(a)(1)(B) claim could not be resolved on a regular bench trial, it reasoned that it makes little sense to deal with such an action by engaging a procedure designed solely to determine "whether there is a genuine issue for trial." The Sixth Circuit adopted suggested guidelines for courts that in essence prescribe a paper review of the record presented to the plan administrator but which it did not tether to any specific procedural rule. Specifically, it directed courts to conduct a de novo review of the record and to make findings of fact and conclusions of law, (2) that evidence outside the record may be offered only in support of a procedural challenge and (3) that Rule 56 motions should not be utilized.

The Sixth Circuit's resolution of the matter does not quite fit with existing Fourth Circuit precedent. The Fourth Circuit law suggests that both summary judgment and bench trial procedures may be applied to ERISA 1132(a)(1)(B) claims on de novo review. Thus, in some instances on de novo review of a benefits decision it is appropriate in the Fourth Circuit to conduct a bench trial. In a review under a differential standard the district court is not making its own finding of facts but reviewing the findings of the administrator to determine whether they are reasonable. Thus it may be that the summary judgment standard, designed to determine whether "there are any genuine factual issues that properly can be resolved" by a fact finder at trial would make little sense when applied on abuse of discretion review and thus is inappropriate.