HARRIS v. FEDERAL EXPRESS CORPORATION LONG TERM DISABILITY PLAN (2021)

United States Court of Appeals, Eighth Circuit.2021-08-20No. No. 21-1049

Summary · law.co

Holding. The district court's grant of summary judgment was affirmed because the plan administrator did not abuse its discretion in interpreting "any compensable employment" to require more than nominal work capacity, and did not abuse its discretion in denying Harris's long-term disability benefits claim.

Timothy Harris sought long-term disability benefits under the Federal Express Corporation Long Term Disability Plan but was denied. He appealed the district court's decision granting summary judgment against him. The appellate court reviewed the plan administrator's interpretation of the term "any compensable employment" and found that the administrator reasonably required more than a minimal ability to work to qualify for benefits. The court determined this interpretation aligned with both the plan's objectives and ERISA's purposes.

The court further concluded that the plan administrator did not act unreasonably in denying Harris's benefits claim. The administrator had obtained new evidence supporting its decision and was not required to rely on Social Security Administration findings or obtain additional vocational evaluations. The court found that medical reports from treating and consulting physicians provided substantial support for the administrator's conclusion that Harris was not disabled under the plan's terms.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether the plan's interpretation of "any compensable employment" requiring more than minimal ability to work was reasonable
Whether the plan administrator abused its discretion in denying long-term disability benefits
Whether plan administrators are bound by Social Security Administration disability determinations

Procedural posture

Harris appealed the district court's grant of summary judgment in his ERISA action challenging the denial of long-term disability benefits by the Federal Express plan administrator.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

[Unpublished]

Timothy Harris appeals following the district courts

adverse grant of summary judgment in his Employee Retirement Income Security Act (ERISA) action arising from the denial of long-term disability (LTD) benefits. Upon careful review, see Carrow v. Standard Ins. Co., 664 F.3d 1254, 1258 (8th Cir. 2012) (de novo review of grant of summary judgment; if plan reserves discretionary power to construe terms or determine eligibility, administrators decision is reviewed for abuse of discretion), we agree with the district court that appellee Federal Express Corporation Long Term Disability Plan (the Plan) did not abuse its discretion in interpreting the term “any compensable employment,” as its interpretation required more than a nominal ability to work, and thus did not conflict with the Plans goals or with ERISAs stated purpose. See McClain v. Eaton Corp. Disability Plan, 740 F.3d 1059, 1067-68 (6th Cir. 2014) (rejecting plaintiffs argument that ability to do part-time sedentary work was “pittance” that was insufficient to find her able to do other work under plan definition of disability); Finley v. Special Agents Mut. Benefit Assn, Inc., 957 F.2d 617, 621 (8th Cir. 1992) (setting out factors to determine whether interpretation of plan terms is reasonable). We also agree that the Plan did not abuse its discretion in denying Harriss claim for LTD benefits. See Johnston v. Prudential Ins. Co. of Am., 916 F.3d 712, 715-16 (8th Cir. 2019) (because plan administrator had new evidence supporting its decision to terminate LTD benefits, it did not err by not obtaining vocational opinion); Carrow, 664 F.3d at 1259 (plan administrator was not bound by Social Security Administrations disability findings, and reports of treating and consulting physicians constituted substantial evidence supporting plan administrators decision that claimant was not disabled).

The judgment is affirmed. See 8th Cir. R. 47B.

FOOTNOTES

. The Honorable Jean C. Hamilton, United States District Judge for the Eastern District of Missouri.

PER CURIAM.