“Under ERISA, when a plan administrator ... has the discretionary authority to determine eligibility for benefits, courts review a decision to deny benefits under the highly deferential arbitrary and capricious standard of review.” Smith v. Fed. Express Corp. Long Term Disability Plan, 991 F.Supp.2d 992, 996 (W.D.Tenn.2014) (quoting McDonald v. Western–Southern Life Ins. Co., 347 F.3d 161, 168–69 (6th Cir.2003) ) (internal quotation marks omitted). “The arbitrary and capricious standard is the least demanding form of judicial review of administrative action.”
Furthermore, courts in this circuit and across the country have repeatedly upheld the language in the very plan at issue here. See, e.g., Oliver v. Aetna Life Ins. Co., 613 Fed. App'x. 892 (11th Cir 2015); Street v. Aetna Life Ins. Co., 188 F.Supp.3d 1279 (M.D. Fl. 2016); Smith v. Federal Express Corp. Long Term Disability Plan, 901 F.Supp.2d 992 (W.D. Tenn. 2014); Weidner v. Federal Express Corp., Civil No. 04-4477 ADM//JSM, 2006 WL 1283799 (D. Minn. May 9, 2006). This Court is likewise not persuaded that the Plan's definition of Total Disability is inherently unreasonable.
Rather, the plan administrator has "discretionary authority to determine eligibility for benefits governed by courts['] examination of benefits denials under the arbitrary and capricious standard of review." Smith v. Fed. Exp. Corp. Long Term Disability Plan, 991 F. Supp. 2d 992, 997 (W.D. Tenn. 2014) (internal quotation marks omitted). Moreover, "although a court must give special weight to the opinions of a claimant's treating physician in social security cases, the same deference does not apply to disability determinations under employee benefit plans governed by ERISA.
However, because the LTD Plan's denial of Plaintiff's benefits was not an abuse of discretion, the argument is now moot, and the Court does not consider the argument here. See Smith v. Fed. Exp. Corp. Long Term Disability Plan, 991 F.Supp.2d 992, 998 (W.D. Tenn. 2014). IT IS SO ORDERED.