Some long-term disability claims are appealed to a United States District Court. If the court upholds the LTD denial, the next step is to appeal the claim to the United States Court of Appeals. For claimants in Florida, Alabama, and Georgia, these appeals go to the Eleventh Circuit. In this article, we discuss the Eleventh Circuit Court’s jurisdiction and the standard of review for long-term disability claims under its jurisdiction.
Jurisdiction of 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, we often shorten the Eleventh Circuit to 11th Cir. or CA11.
The Standard of Review In Eleventh Circuit Long-Term Disability Appeals
Under the Employee Retirement Income Security Act’s (ERISA) 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 plan’s terms. Although ERISA 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 of review 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 judgment.
- If the administrator’s decision is, in fact, “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 exist, determine if he operated under a conflict of interest.
- If there is no conflict, end the inquiry and affirm the decision.
- If there is a conflict, the conflict should merely be a factor for the court to consider when determining whether an administrator’s decision was arbitrary and capricious.
Ortiz Law Firm Advocates For Long-Term Disability Claimants
Let us assist you in determining your eligibility for benefits and guiding you through the appeal process. We are based in Florida but represent disability claimants throughout the United States. If you want to discuss your denied claim with a long-term disability insurance attorney, contact us online or at (888) 321-8131 to schedule your free case evaluation.
