Cooper v. Metro. Life Ins. Co.

26 Citing cases

  1. Anyanwu v. Ascension Health

    Case No. 4:17-CV-02722-NCC (E.D. Mo. May. 22, 2019)   Cited 1 times

    A decision is reasonable and this Court must affirm "if a reasonable person could have reached a similar decision, given the evidence before him, not that a reasonable person would have reached that decision." Cooper v. Metro. Life Ins. Co., 862 F.3d 654, 660 (8th Cir. 2017) (emphasis in original) (citation and quotation omitted); Prezioso, 748 F.3d at 805; Kraus v. Ascension Health Long Term Disability Plan, No. 4:15 CV 718 JMB, 2016 WL 4061880, at *7 (E.D. Mo. July 29, 2016). Here, the plan confers discretionary authority on the Claims Administrator, in this case Sedgwick, to determine eligibility for receipt or continued receipt of benefits and to make all claims determinations.

  2. Roebuck v. USAble Life

    992 F.3d 732 (8th Cir. 2021)   Cited 17 times   1 Legal Analyses

    Courts determine what weight to give an insurer's conflict of interest on a case-by-case basis, and we give greater weight to situations in which (1) "the insurer's claims review process was tainted by bias"; (2) the medical professionals reviewing the claim were employed by the insurer; (3) the medical professionals reviewing the claim had their compensation tied to their findings; or (4) "the insurer acted as little more than a rubberstamp for favorable medical opinions." Boyd , 879 F.3d at 320–21 (quoting Cooper v. Metro. Life Ins. Co. , 862 F.3d 654, 661 (8th Cir. 2017) ). "But when the record ‘contains no evidence about [the plan administrator]’s "claims administration history or its efforts to ensure that claims assessment is not affected by the conflict," [the court] only "give[s] the conflict some weight." ’ " Id . at 321 (alterations in original) (quoting Donaldson v. Nat'l Union Fire Ins. Co. of Pittsburgh , 863 F.3d 1036, 1039 (8th Cir. 2017) ).

  3. Nauss v. Sedgwick Claims Mgmt. Servs.

    4:20-CV-00304 JAR (E.D. Mo. Nov. 9, 2021)   Cited 1 times

    If, however, an ERISA plan expressly grants discretionary authority to the administrator or fiduciary to make benefits determinations and interpret plan terms, the Court reviews the administrator's benefits determination for an abuse of discretion. Roebuck, 992 F.3d at 736; see also Cooper v. Metro. Life Ins. Co., 862 F.3d 654, 660 (8th Cir. 2017) (same).

  4. Sepulveda-Rodriguez v. MetLife Grp., Inc.

    8:16CV507 (D. Neb. Dec. 28, 2017)   1 Legal Analyses

    "In general, a claim administrator's denial of benefits is subject to de novo review by the district court." Cooper v. Metro. Life Ins. Co., 862 F.3d 654, 660 (8th Cir. 2017); seeBruch, 489 U.S. at 115. Where the plan grants the administrator or fiduciary "discretionary authority" to determine eligibility for benefits, however, the standard of review is relaxed, and abuse of discretion becomes the appropriate benchmark.

  5. Boyd v. Conagra Foods, Inc.

    879 F.3d 314 (8th Cir. 2018)   Cited 16 times   1 Legal Analyses
    Recognizing abrogation of Woo

    To the extent Boyd contends that Woo governs because a "conflict of interest influenced ConAgra's decision to deny Boyd's claim and appeal," this argument is foreclosed by Glenn. See Glenn, 554 U.S. at 115–17, 128 S.Ct. 2343 ; see also Cooper v. Metro. Life Ins., 862 F.3d 654, 660 (8th Cir. 2017) ("[Eighth Circuit] precedent ... has consistently rejected the notion that the mere presence of a potential conflict of interest is sufficient to warrant a less deferential standard.").Boyd also argues that Woo governs because there was a procedural irregularity when Schaefer, who met with Boyd about his Good Reason letters, misled him by falsely stating that he retained decision-making authority over the Red Card Project. "Our circuit has not definitively resolved the impact of Glenn on the ‘procedural irregularity component’ " of Woo. Waldoch v. Medtronic, Inc., 757 F.3d 822, 830 n.3 (8th Cir. 2014) (quoting Wrenn, 636 F.3d at 924 n.6 ).

  6. Wilkins v. Ascension Health Long-Term Disability Plan

    4:22-cv-00428-SEP (E.D. Mo. Mar. 31, 2024)   1 Legal Analyses

    Johnson v. Metro. Life Ins. Co., 437 F.3d 809, 814 (8th Cir. 2006); see also Cooper v. Metro. Life Ins. Co., 862 F.3d 654, 662 (8th Cir. 2017) (same). C. Sedgwick did not improperly ignore or reject evidence of Plaintiff's disability.

  7. Hounihan v. Proctor & Gamble Disability Comm.

    No. 1:18-cv-00010-AGF (E.D. Mo. Jun. 20, 2019)

    "In general, a claim administrator's denial of benefits is subject to de novo review by the district court. Where the plan grants the administrator or fiduciary 'discretionary authority' to determine eligibility for benefits, however, the standard of review is relaxed, and abuse of discretion becomes the appropriate benchmark." Cooper v. Metro. Life Ins. Co., 862 F.3d 654, 660 (8th Cir. 2017). "To determine whether the benefit plan gives the administrator or fiduciary discretionary authority, courts must look for explicit discretion-granting language in the policy or in other plan documents."

  8. Leirer v. Proctor & Gamble Disability Benefit Plan

    Case No. 4:15CV00122 AGF (E.D. Mo. Sep. 29, 2017)   Cited 1 times
    Applying the less stringent definition of total disability

    Where the plan grants the administrator or fiduciary 'discretionary authority' to determine eligibility for benefits, however, the standard of review is relaxed, and abuse of discretion becomes the appropriate benchmark." Cooper v. Metro. Life Ins. Co., 862 F.3d 654, 660 (8th Cir. 2017). "To determine whether the benefit plan gives the administrator or fiduciary discretionary authority, courts must look for explicit discretion-granting language in the policy or in other plan documents.

  9. Leirer v. Proctor & Gamble Disability Benefit Plan

    910 F.3d 392 (8th Cir. 2018)   Cited 6 times

    The Plan grants the company discretionary authority over the Plan’s administration, which would be sufficient on its own to trigger abuse-of-discretion review. See Cooper v. Metro. Life Ins. Co., 862 F.3d 654, 660 (8th Cir. 2017). In Woo v. Deluxe Corp., however, we stated that courts may apply a less deferential standard of review if there are procedural irregularities in the administrative process.

  10. Hestir v. USAble Life

    490 F. Supp. 3d 1344 (E.D. Ark. 2020)

    Id.Cooper v. Metro. Life Ins. Co. , 862 F.3d 654, 661 (8th Cir. 2017).Manning , 604 F.3d at 1038.