Case Name: Susan Till v. Lincoln National Life Insurance Company
Court: U.S. Court of Appeals for the Eleventh Circuit, on appeal from the U.S.D.C. for the Middle District of Alabama.
Date of Decision: January 30, 2017
Type of Claim: Long-Term Disability under the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. § 1001 et seq.
Insurance Company: Lincoln National Life Insurance Company
Claimant’s Occupation / Job Position: A radiology technologist
Disabilities: Till had a long history of back problems.
Procedural History: Lincoln denied the Plaintiff’s LTD claim. The plaintiff filed a lawsuit in Federal Court. Lincoln filed a motion for judgment as a matter of law, to which Till responded with a motion for summary judgment. After a full briefing, the district court entered an order granting Lincoln’s motion and denying Till’s. The district court also subsequently denied Till’s motion to reconsider. After carefully considering the record on appeal, the parties’ briefs, and the relevant law, the Eleventh Circuit concluded that the district court decision is due to be affirmed.
Issues: Lincoln concedes on appeal that the “ultimate issue for this Court . . . is whether Lincoln’s decision to deny Till’s claim for benefits was at least a reasonable [one],” and accordingly, we will forego an analysis of whether the administrator’s decision was de novo wrong under the first prong of our analysis. Likewise, it seems clear to us at the second step—and Till does not credibly dispute—that Lincoln had the discretionary authority under the clear language of the policy “to manage the Policy, interpret its provisions, administer claims and resolve questions arising under it.” Accordingly, we will begin our analysis at step three and determine whether Lincoln’s decision to deny the claim was arbitrary and capricious.
Holdings: (1) We have little trouble concluding that Lincoln’s final decision in this case was reasonable. The plan at issue in this case placed the burden on Till to provide adequate documentation to support her claim. Lincoln adequately considered all of the medical information that had been submitted by Till and gathered through Lincoln’s own independent investigation to conclude—with the concurrence of two independent and board-certified specialists—that Till had failed to make a sufficient showing of disability under the plan.
While we certainly take notice of the differing opinions offered by the doctors for both Till and Lincoln, nothing in the record suggests to us that the administrator’s decision to afford more or less weight to those opinions was arbitrary and capricious.
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This includes Till’s disagreement with, among other things: (1) Lincoln’s treatment of a medical opinion that she could not undergo a physical exam; (2) Lincoln’s determination that her condition was not surgical; and (3) Lincoln’s determination that she was capable of light work. In light of the entire administrative record, there is simply no evidence by which we could conclude that the administrator’s conclusion was arbitrary and capricious.
(2) Additionally, the description of Till’s occupation was committed to the sound discretion of the administrator to be determined with reference to how it is “performed in the national workforce; not as performed for a certain firm or at a certain work site.” Even assuming that Lincoln’s classification of Till’s occupation was based entirely on the much-maligned Dictionary of Occupational Titles (“DOT”) 5, this Court and several other circuit courts have held that Lincoln was entitled to rely on the occupational descriptions contained therein. See Stiltz v. Metro. Life Ins. Co., 244 F. App’x 260, 2007 WL 1600036, at *3 (11th Cir. June 5, 2007) (holding that where “[t]he clear plan language allowed [the administrator] to look beyond the requirements of ‘the specific position’ [plaintiff] held, [the administrator] was entitled to rely on the Dictionary of Occupational Titles”). Given that Lincoln was contractually required to consider the manner in which this job is performed in the national workforce, its decision to credit the DOT over Till’s personal experience was not only reasonable but also undeniably correct.
(3) Lastly, considering Lincoln’s conflict of interest as a factor at the final stage of our analysis, we cannot conclude that the conflict rendered the decision arbitrary and capricious. Lincoln’s conflicts of interest are typical of the insurance industry, and we have previously rejected attempts to prove that a benefits “decision was tainted by self-interest” based on these standard industry practices.
(4) As the district court exhaustively cataloged, Till’s conclusory allegation that she was denied a full and fair review of her claim is without support in the record. Lincoln provided Till with written notice of its decision—and the basis therefor—and provided her with a meaningful opportunity to dispute its findings. Rather than taking the opportunity to submit additional medical evidence prior to Lincoln’s final decision, Till responded to this notice by focusing almost entirely on the documentation that had already been provided. Those arguments, which are largely echoed on appeal here, speak to the merits of a decision which, we have already decided above, was reasonable.
Summary: Given the deference that this Court owes to the discretionary decisions of a plan administrator, we cannot conclude that the denial of benefits was an abuse of discretion or that the procedures adopted by Lincoln denied Till a full and fair review. Accordingly, the well-reasoned decision of the district court is AFFIRMED.
Disclaimer: This case was not handled by disability attorney Nick Ortiz. The court case is summarized here to give readers a better understanding of how Federal Courts decide long-term disability ERISA claims.
Here is a PDF copy of the decision: Till v. Lincoln National
