Eleventh Circuit Long Term Disability Claims
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
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. Melech v. Life Insurance Company of North America, 739 F.3d 663, 672 (11th Cir. 2014). 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.
Blankenship v. Metropolitan Life Ins. Co., 644 F.3d 1350, 1354 (11th Cir. 2011).
The Ortiz Law Firm represents claimants throughout the Eleventh Circuit, particularly in Florida. Mr. Ortiz represents claimants from anywhere in Florida, including (but not limited to) the following cities: Jacksonville, Miami, Tampa, Saint Petersburg, Orlando, Hialeah, Tallahassee, Fort Lauderdale, Port Saint Lucie, Pembroke Pines and Pensacola.