Legal Summary: Myers v. Bridgestone Long-Term Disability Plan
Myers v. Bridgestone Long-Term Disability Plan
No. 4:03-cv-60 (E.D. Tenn. Jan. 17, 2007)
Our client worked as a technician at Bridgestone Corporation before a disability rendered her unable to work.
Under the terms of Bridgestone’s plan, the Disability Committee of the Pension Board determines eligibility for long-term benefits. If someone is denied benefits, the employee can appeal the claim to the Pension Board.
Our client initially received benefits from Bridgestone for two years before the Board decided she was no longer disabled. She appealed this decision, but the Board denied again. Per Bridgestone’s policy, an employee must prove that they are rendered disabled from gainful employment under the any occupation policy definition. Additionally, one must be approved for Social Security disability benefits “on or before the end of the initial duration.”
We sent Bridgestone the approval letter from the SSA, indicating our client was receiving benefits at this time.
Our client’s treating physicians determined that her condition rendered her disabled from gainful employment under the any occupation policy definition.
When the Board refused to change its decision, we sued in court on behalf of our client.
The court reviewed Bridgestone’s decision and our client’s appeal under the arbitrary and capricious standard. Under this standard, the court must decide if the insurer acted reasonably when denying a claimant’s benefits.
An insurer must consider evidence provided by the claimant and their treating physicians. Plan administrators must review “the quality and quantity of the medical evidence and the opinions on both sides of the issues.” (McDonald v. Western-Southern Life Insurance Company, 347 F.3d 161, 172 (6th Cir.2003).) An administrator’s decision is not considered arbitrary and capricious if they are “in rational light of the Plan’s provisions.” (Elliott v. Lockheed Martin Energy Systems, 61 F.Supp. 745, 751 (E.D.Tenn.1999).) The court found that Bridgestone acted arbitrarily and capriciously when considering the medical evidence at hand.
The court was “extremely suspect” of a physician hired by Bridgestone. The Disability Committee relied entirely upon this physician’s opinion, but he never examined or treated our client and is not an expert in the specific field concerning her disability. Furthermore, there is “no written record” of what this physician told the Disability Committee, yet this decision was based entirely upon his comments.
The court explained, “[t]o conclude that Dr. Moten’s oral presentation constitutes substantial evidence to support the defendants’ determination would make that determination essentially unreviewable. Because defendants’ determination that plaintiff is no longer disabled is without any written support, the court finds that that determination is arbitrary and capricious.” Myers v. Bridgestone, 4;03-cv-60, 5, 2005 Westlaw 1240603, 5 (E.D.TN March 1, 2005).
We also argued that Bridgestone should pay our client’s attorneys’ fees and costs, pursuant to ERISA code 29 U.S.C. § 1132(G)(1). Given Bridgestone’s failure to present any written medical opinion, the court ruled that it was appropriate for the insurer to cover these fees.
The court ruled in our favor, determining that Bridgestone’s decision was arbitrary and capricious and that our client was owed her past due benefits. The court ordered the parties to confer and report back within 30 days if they could not settle the benefits, costs, and attorneys’ fees owed.
