{"id":7502,"date":"2020-04-08T14:57:20","date_gmt":"2020-04-08T19:57:20","guid":{"rendered":"https:\/\/www.nickortizlaw.com\/?p=7502"},"modified":"2024-01-30T17:07:42","modified_gmt":"2024-01-30T22:07:42","slug":"killen-v-reliance-standard-court-finds-there-was-no-abuse-of-discretion","status":"publish","type":"post","link":"https:\/\/www.nickortizlaw.com\/killen-v-reliance-standard-court-finds-there-was-no-abuse-of-discretion\/","title":{"rendered":"Killen v. Reliance Standard – Court Finds There Was No Abuse of Discretion"},"content":{"rendered":"\n
Case Name:<\/strong> Killen v. Reliance Standard Life Insurance Company<\/p>\n\n\n\n Court:<\/strong> United States Court of Appeals for the Fifth Circuit, Appeal from the United States District Court for the Northern District of Texas<\/p>\n\n\n\n Type of Claim: <\/strong>Long-Term Disability<\/a><\/p>\n\n\n\n Insurance Company:<\/strong> Reliance Standard Life Insurance Company (\u201cReliance Standard\u201d)<\/a><\/p>\n\n\n\n Claimant\u2019s Employer:<\/strong> Covenant Health Systems (\u201cCovenant\u201d)<\/p>\n\n\n\n Disabilities:<\/strong> Neck<\/a>, shoulder, and upper back pain<\/a>.<\/p>\n\n\n\n Benefits Paid?<\/strong> Long-term disability benefits were initially approved and then cut off or terminated after two years when the definition of \u201ctotally disabled\u201d changed such that the claimant had to prove she was incapable of performing the material duties of any occupation for which she is qualified by way of education, training, or experience<\/p>\n\n\n\n Issues: <\/strong>The central issue raised in this cause of action is whether Reliance Standard abused its discretion in denying the claimant\u2019s long-term disability benefits after two years.<\/p>\n\n\n\n Holding: <\/strong>The Court affirmed the district court\u2019s decision granting summary judgment to Reliance Standard on the ground that it did not abuse its discretion in denying the claimant\u2019s long-term disability benefits. In other words, the Court ruled in favor of the insurance company.<\/p>\n\n\n\n Summary: <\/strong>The Court held that there was substantial evidence to support Reliance Standard\u2019s decision to deny long-term disability benefits to the Plaintiff:<\/p>\n\n\n\n[The Plaintiff] Killen first challenges the district court\u2019s finding that substantial evidence supported the plan\u2019s denial of benefits. Substantial evidence is \u201cmore than a scintilla, less than a preponderance, and is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.\u201d Id.<\/em> (internal quotation marks and citation omitted). Killen claims that the Plan language requires Reliance Standard to show that she can perform all of the job duties of a sedentary vocation full-time before discontinuing benefits. While it might have shown she could perform sedentary work, she argues, Reliance Standard never showed she could do so full-time. Additionally, she claims the district court misconstrued the medical evidence and ignored objective documentation of her pain. \u201cMost disputed claims for disability insurance benefits are awash in a sea of medical evidence, often of contradictory nature,\u201d 10A Couch on Ins. \u00a7 147:33, and this case is no different. Indeed, counsel for Killen admitted as much at oral argument. Courts frequently hear cases like this, where the plaintiff\u2019s treating physicians generally support a finding of disability, and the defendant\u2019s vocational specialists and independent medical examiners disagree.<\/p>\n\n\n\n