Q: When a court reviews an ERISA disability dispute, and looks at the plan, how is it to read the plan it the language is ambiguous?

A: Courts considering eligibility for benefits under an ERISA plan generally consider only the plain meaning of the language of the plan. Kress v. Food Employers Labor Relations Ass'n, 391 F.3d 563, 568 (4th Cir. 2004) (holding that courts will enforce the plain language of an ERISA plan in accordance with its literal meaning).

Any ambiguity in an ERISA plan "is construed against the drafter of the plan, and it is construed in accordance with reasonable expectations of the insured."