Catledge v. Aetna Life Ins. Co.

4 Citing cases

  1. Refaey v. Aetna Life Ins. Co.

    467 F. Supp. 3d 328 (W.D.N.C. 2020)   Cited 2 times

    "The court considers this allocation of the burden of proof when conducting a review of the decision of a plan fiduciary, although it must do so in light of the degree of discretion under which the fiduciary acted." Catledge v. Aetna Life Ins. Co., 594 F. Supp. 2d 610, 624 (D.S.C. 2009). Plaintiff has failed to prove that Aetna's decision was unreasonable under the Booth factors.

  2. Berdeau v. Schaeffler Grp., U.S. Inc.

    C/A No.: 4:17-cv-02744-DCC (D.S.C. May. 16, 2019)

    The Court finds that Plaintiff had the burden of proving that the services he was requesting were Medically Necessary and therefore a "Covered Expense" under the terms of the Plan. AR 90. If the claimant satisfied this burden, the burden shifted to the Plan to show that some exclusion applied which precluded payment of benefits. Catledge v. Aetna Life Ins. Co., 594 F. Supp. 2d 610 (D.S.C. 2009); see also Band v. Paul Revere, 14 F. App'x 210 (4th Cir. 2001) (a plaintiff has the burden of proving entitlement to benefits the terms of an ERISA plan); Tucci v. First Unum Life Ins. Co., 446 F. Supp. 2d 473 (D.S.C. 2006); Fuja v. Benefit Trust Life Insurance Company, 18 F.3d 1405, 1408 (7th Cir. 1994) (ERISA plaintiff has burden of proving coverage); see also Gable v. SweetheartCompany, Inc., 35 F.3d 851, 855-56 (4th Cir. 1994) (ERISA plaintiff bears the burden of proving their employer's ERISA plan contains a promise to provide vested benefits), Lown v. Continental Cas. Co., 238 F.3d 543 (4th Cir. 2001) (applying de novo standard of review holding that insurer properly denied the plaintiff's claim where the plaintiff failed to meet her burden of proving that she was totally disabled under the terms of a long-term disability plan). 3. Plaintiff's Claim

  3. Harman v. Aetna Life Ins. Co.

    C/A No. 7:11-3420-TMC (D.S.C. Jan. 14, 2013)

    (Compl. ¶¶ 3, 4, 9). Harman relies upon Catledge v. Aetna Life Ins. Co., 594 F.Supp.2d 610 (D.S.C. 2009). In Catledge, the court, after concluding that Aetna improperly denied a claim, found the record inadequate to support the payment of benefits and therefore remanded the matter for further review.

  4. Anderson v. Reliance Standard Life Ins. Co.

    Case No.: WDQ-11-1188 (D. Md. Jan. 5, 2012)   Cited 4 times
    Ordering limited discovery into the alleged relationships among “the plan administrator, the insurer and various medical providers”

    Id. Accord Worsley v. Aetna Life Ins. Co., 780 F. Supp. 2d 397, 408 (W.D.N.C. 2011) ("The Court thus finds it appropriate to consider the very limited evidence presented by Aetna regarding the procedural safeguards it has implemented to ensure that its inherent structural conflict of interest does not dead to biased claim determinations."); McDonough v. Aetna Life Ins. Co., No. 3:09cv00071, 2011 WL 1418878 (W.D. Va. Apr. 8, 2010) ("[B]ecause the conflict of interest must be evaluated to determine what role it should play in a reviewing court's analysis of a fiduciary's decision, . . . limited discovery on the nature of the conflict in this case is not 'clearly erroneous and contrary to law.'") (quoting Fed. R. Civ. P. 72(a)); Catledge v. Aetna Life Ins. Co., 594 F. Supp. 2d 610 (D.S.C. 2009) ("In light of the paucity of evidence as to the basis of Aetna's 'intent' determination, and comments in Glenn regarding matters which might be considered in weighing the impact of a conflict of interest, this court allowed limited discovery in this matter in the form of two depositions of the key individuals involved in the decisionmaking process. The depositions were further limited as to subject matter.").