{"id":7521,"date":"2020-04-08T19:29:44","date_gmt":"2020-04-09T00:29:44","guid":{"rendered":"https:\/\/www.nickortizlaw.com\/?p=7521"},"modified":"2024-01-30T15:18:36","modified_gmt":"2024-01-30T20:18:36","slug":"lash-v-reliance-standard-court-dismisses-case-for-failure-to-state-claim-against-matrix","status":"publish","type":"post","link":"https:\/\/www.nickortizlaw.com\/lash-v-reliance-standard-court-dismisses-case-for-failure-to-state-claim-against-matrix\/","title":{"rendered":"Lash v. Reliance Standard – Court Dismisses Case For Failure to State Claim Against Matrix"},"content":{"rendered":"\n

Case Name: <\/strong>Kimberley Lash v. Reliance Standard Life Insurance Co, et al.<\/p>\n\n\n\n

Court: <\/strong>U.S. District Court for the Eastern District of Pennsylvania<\/p>\n\n\n\n

Date of Decision: <\/strong>April 4, 2017<\/p>\n\n\n\n

Type of Claim:\u00a0<\/strong>Long-Term Disability<\/a> under the Employment Retirement Income Security Act of 1974 (\u201cERISA\u201d)<\/a><\/p>\n\n\n\n

Insurance Company:\u00a0<\/strong>Reliance Standard Life Insurance Company<\/a>\u00a0(\u201cReliance Standard\u201d).\u00a0Matrix Absence Management, Inc.<\/a>\u00a0was the claim’s third-party administrator (\u201cTPA\u201d).<\/p>\n\n\n\n

Claimant\u2019s Employer: <\/strong>Temple University Health System<\/p>\n\n\n\n

Claimant\u2019s Occupation \/ Job Position: <\/strong>Payroll Supervisor<\/p>\n\n\n\n

Disabilities: <\/strong>An MRI performed in May 2012 revealed that Lash had a tumor in her lower back. Lash had surgery to remove the tumor on May 24, 2012, which caused her to become totally paralyzed in her lower extremities<\/a>.<\/p>\n\n\n\n

Benefits Paid?\u00a0<\/strong>Yes \u2013 for the first two years under the \u201cown occupation<\/a>\u201d definition of disability. Matrix initially approved Lash\u2019s claim for long-term disability benefits. At that time, Matrix informed her that \u201cin order to be eligible for benefits beyond 24 months<\/a>,\u00a0she had to be disabled from performing the material duties of any occupation beginning August 3, 2014.\u201d To determine Lash\u2019s continued eligibility, Matrix collected documentation from her medical providers and had its Nurse Case Manager review her claim on April 10, 2014.<\/p>\n\n\n\n

Basis For Denial \/ Termination of Benefits:\u00a0<\/strong>On February 6, 2015, Matrix informed Lash that her claim for long-term disability benefits was denied, as Matrix determined that she could perform other occupations despite her disability.<\/p>\n\n\n\n

Procedural History: <\/strong>Lash appealed the termination of benefits decision on February 22, 2015, after which Reliance required her to submit to an Independent Medical Examination<\/a>. On May 22, 2015, Reliance notified Lash that it had conducted an independent review and upheld the decision to deny benefits.<\/p>\n\n\n\n

Plaintiff Kimberly Lash thereafter brought a civil action against Temple University Health System, her former employer, Reliance Standard Life Insurance Company, the insurer of Temple\u2019s Group Long Term Disability Insurance Plan (the \u201cPlan\u201d), and Matrix Absence Management, Inc. Matrix and Reliance moved to dismiss the First Amended Complaint. The District Court granted and denied the Motion to Dismiss in part.<\/p>\n\n\n\n

Primary Issue:\u00a0<\/strong>The moving Defendants seek to dismiss Counts I and II against Matrix, contending that Matrix is an improper Defendant in Lash\u2019s claims asserted under 29 U.S.C. \u00a7 1132(a)(1)(B). Under ERISA, an insurance plan participant may bring a civil action \u201cto recover benefits due to him under the terms of his plan, to enforce his rights under the terms of the plan, or to clarify his rights to future benefits under the terms of the plan.\u201d 29 U.S.C. \u00a7 1132(a)(1)(B).<\/p>\n\n\n\n

Holding:\u00a0<\/strong>For the aforementioned reasons, we conclude that the First Amended Complaint, like the original Complaint, fails to allege that Matrix is a proper Defendant to Lash\u2019s claim for benefits asserted under \u00a7 1132(a)(1)(B). Rather, because the First Amended Complaint alleges that Reliance made the final decision to deny Lash\u2019s claim for long-term disability benefits, it does not plausibly allege that Matrix exercised the requisite control over the administration of benefits to support a claim against Matrix under \u00a7 1132(a)(1)(B). Accordingly, the Motion to Dismiss Counts I and II for failure to state a claim against Matrix is granted.<\/p>\n\n\n\n

Disclaimer:<\/strong> This case was not handled by disability attorney Nick A. Ortiz. The court case is summarized here to give readers a better understanding of how Federal Courts decide long-term disability ERISA claims.<\/p>\n\n\n\n

Here is a copy of the decision in PDF: Lash v. Reliance<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"

The Complaint alleged that Reliance made the final decision to deny Lash\u2019s claim. The claimant failed to state a claim against Matrix is granted.<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_genesis_hide_title":false,"_genesis_hide_breadcrumbs":false,"_genesis_hide_singular_image":false,"_genesis_hide_footer_widgets":false,"_genesis_custom_body_class":"","_genesis_custom_post_class":"","_genesis_layout":"","footnotes":""},"categories":[1],"tags":[259],"_links":{"self":[{"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/posts\/7521"}],"collection":[{"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/comments?post=7521"}],"version-history":[{"count":0,"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/posts\/7521\/revisions"}],"wp:attachment":[{"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/media?parent=7521"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/categories?post=7521"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/tags?post=7521"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}