Some long-term disability claims are appealed to the Eleventh Circuit. In this article, we discuss the jurisdiction of the Eleventh Circuit Court and the standard of review for Eleventh Circuit long-term disability claims.
Jurisdiction for the Eleventh Circuit Court
The United States Court of Appeals for the Eleventh Circuit is a federal court with appellate jurisdiction (authority to hear appeals) from the following district courts in Florida, Alabama, and Georgia:
- Middle District of Florida
- Northern District of Florida
- Southern District of Florida
- Middle District of Alabama
- Northern District of Alabama
- Southern District of Alabama
- Middle District of Georgia
- Northern District of Georgia
- Southern District of Georgia
When referenced in case citations the Eleventh Circuit is often shortened to 11th Cir. or CA11.
Standard of Review in Eleventh Circuit LTD Cases
Under ERISA’s civil enforcement provisions, a long term disability plan participant may bring a federal lawsuit against the plan administrator to recover wrongfully denied benefits due to the claimant under the terms of the plan. Although ERISA itself does not provide any standards for a court’s review of a plan administrator’s denial or termination of benefits, the United States Supreme Court has articulated a framework for judicial review, which the Eleventh Circuit has distilled into a six-part test. Thus, a district court in the 11th Circuit reviewing a plan administrator’s benefits decision should conduct the following multi-step analysis:
- Apply the de novo standard to determine whether the claim administrator’s benefits-denial decision is “wrong” (i.e., the court disagrees with the administrator’s decision); if it is not, then end the inquiry and affirm the decision.
- If the administrator’s decision in fact is “de novo wrong,” then determine whether he was vested with discretion in reviewing claims; if not, end judicial inquiry and reverse the decision.
- If the administrator’s decision is “de novo wrong” and he was vested with discretion in reviewing claims, then determine whether “reasonable” grounds supported it (hence, review his decision under the more deferential arbitrary and capricious standard).
- If no reasonable grounds exist, then end the inquiry and reverse the administrator’s decision; if reasonable grounds do exist, then determine if he operated under a conflict of interest.
- If there is no conflict, then end the inquiry and affirm the decision.
- If there is a conflict, the conflict should merely be a factor for the court to take into account when determining whether an administrator’s decision was arbitrary and capricious.
Ortiz Law Firm Provides Aggressive Representation to Long Term Disability Claimants
If you’d like to speak to one of our very experienced Long Term Disability Insurance Attorneys about your denied claim, contact us at (888) 321-8131 to schedule a consultation. Although based in Florida, the Ortiz Law Firm represents claimants across the United States. We can help you evaluate your claim to determine whether you qualify for Long Term Disability Benefits and how to navigate through the appeals process if your claim has been denied.
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