Opinion
CASE NO. 1: 06 CV 1321.
May 17, 2007
MEMORANDUM OPINION AND ORDER
This matter comes before the Court upon a Motion for Judgment filed by Defendants Ameritech Sickness and Accident Disability Benefit Plan ("the STD Plan") and AT T Teleholdings, Inc. fka Ameritech Corporation ("Ameritech"). (ECF # 22.)
AT T Teleholdings, Inc. fka Ameritech Corporation ("Ameritech") was incorrectly identified in the Complaint as SBC Ameritech Corporation.
I. BACKGROUND
In May 2006, Plaintiff Loretta Wilson filed a Complaint against Defendants, alleging wrongful denial of disability benefits in violation of the Employee Retirement Income Security Act of 1974, as amended ("ERISA"), 29 U.S.C. §§ 1001 et seq. (ECF # 1 at ¶ 1.) More specifically, in the sole cause of action, Plaintiff alleges the following:
[Ameritech] as administrator of the [STD Plan] has wrongfully denied Plaintiff's claim for benefits and Defendant Plan has wrongfully withheld long-term disability benefits to Plaintiff in violation of the Plan and ERISA. Both the Plan and [Ameritech] are liable to Plaintiff under ERISA.
( Id. at ¶ 27.) Plaintiff seeks, inter alia, a declaration that Defendants have wrongfully denied her disability benefits in violation of ERISA and an award of the benefits that she alleges have been wrongfully denied, with interest. ( Id. at 5.)
On February 16, 2007, Defendants filed the instant Motion for Judgment, moving the Court "for an entry of judgment upholding and affirming the decision of the Ameritech Employees' Benefit Committee, which upheld the denial of further short-term disability benefits to Plaintiff under STD Plan." (ECF # 22 at 1.) Defendants further argue that any claim for long-term disability benefits should be dismissed because Plaintiff failed to exhaust her administrative remedies. ( Id.)
II. DISCUSSION
In Firestone Tire Rubber Co. v. Bruch, 489 U.S. 101 (1989), the Supreme Court considered what standard of review is appropriate when a plaintiff brings a challenge involving a denial of ERISA benefits in district court. In addressing this issue, the Supreme Court held that challenges to a plan administrator's decision must be reviewed de novo by the district court. Bruch, 489 U.S. at 113-14. The Supreme Court also provided, however, an exception to the de novo standard of review in certain cases. See Perry v. Simplicity Engineering, 900 F.2d 963, 964 (6th Cir. 1990) (citing Bruch, 489 U.S. at 114). In particular, the Supreme Court stated that if "the benefit plan expressly gives the plan administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the plan's terms," then the district court shall review the plan administrator's decision under the arbitrary and capricious standard. Id.; see also Borda v. Hardy, Lewis, Pollard Page, P.C., 138 F.3d 1062 (6th Cir. 1998) (citing Bruch and thus finding that the district court properly applied the arbitrary and capricious standard of review when the benefit plan at issue contained a broad grant of discretionary authority to the plan administrator).
Under the arbitrary and capricious standard, determinations made by the plan administrator must be upheld if they are deemed to be rational in light of the plan's provisions. Borda, 138 F.3d at 1065. Furthermore, the arbitrary and capricious standard is the least demanding review of an administrative action. See Davis v. Kentucky Fin. Cos. Retirement Plan, 887 F.2d 689, 693 (6th Cir. 1989). Therefore, when it is possible to offer a reasoned explanation for a plan administrator's decision based upon the evidence, that decision is not arbitrary and capricious. See id.
In addition, in Wilkins v. Baptist Healthcare System, Inc., 150 F.3d 609 (6th Cir. 1998), the Sixth Circuit provided further insight with respect to the procedures governing a claim challenging the plan administrator's denial of benefits. In particular, the Sixth Circuit made clear that: (1) the district court should not adjudicate the action as if it were a bench trial; and (2) summary judgment procedures should not be used in the disposition of the claim of a denial of benefits. Id. at 617. Rather, the Wilkins Court instructed the district court to conduct the review based solely upon the administrative record existing in the case. Id.
In instant case, there is no dispute that the STD Plan and the Ameritech Long Term Disability Plan ("the Ameritech LTD Plan") expressly grant the Ameritech Employees' Benefit Committee ("the Committee") wide-ranging authority to determine eligibility for benefits or to construe the Plans' terms. Considering the Plan language in the context of the relevant case law, this Court finds the arbitrary and capricious standard to be applicable to this matter. More specifically, the Court shall review the Committee's determination denying Plaintiff disability benefits using the arbitrary and capricious standard of review.
Under this standard, this Court is charged with the responsibility of merely determining whether the Committee's decision is rational in light of the Plan's provisions. Given that this standard is the least demanding review of an administrative action, the Court need only find that a reasoned explanation for the Committee's decision exists in the evidence. The record reflects that, after examining Plaintiff, the Independent Medical Evaluation ("IME") physician opined that Plaintiff could return to sedentary work, with certain physical restrictions. After Ameritech determined that it could accommodate the restrictions, and Plaintiff failed to present any objective medical documentation contrary to the opinion of the IME physician, Ameritech denied Plaintiff further short-term disability benefits. This evidence, considered on appeal by the Committee, led to the decision upholding the denial of short-term disability benefits. Stated another way, the Committee based its decision on the fact that Plaintiff submitted no objective medical findings to contradict the results of the IME. Hence, the Committee determined that Plaintiff was not disabled under the STD Plan. Given the broad discretion granted to the Committee, this Court simply cannot find that the Committee's decision to deny Plaintiff further short-term disability benefits was arbitrary and capricious.
With respect to Plaintiff's claim for long-term disability benefits, as an initial matter, Plaintiff's claim is not properly before the Court because she failed to appeal Ameritech's determination under the Ameritech LTD Plan to the Committee. However, even assuming that Plaintiff's claim were properly before the Court, in order to be eligible under the Ameritech LTD Plan, Plaintiff was required to first qualify for 52 weeks of short-term disability benefits under the STD Plan. Accordingly, Ameritech properly determined that, because Plaintiff failed to qualify for the requisite 52 weeks, she was not entitled to disability benefits under the Plan. Based on the foregoing, the Court finds Plaintiff's claim based on a denial of long-term disability benefits to be without merit.
III. CONCLUSION
For the reasons set forth above, the Court finds Defendants' Motion for Judgment to be meritorious. (ECF # 22.) Consistent with that finding, Plaintiff Loretta Wilson's Complaint is hereby DISMISSED in its entirety. (ECF # 1.) This case is TERMINATED.
IT IS SO ORDERED.