Holt v. Life Ins. Co. of N. Am.
Mar 18, 2015OUTCOME: Plaintiff's claim for benefits was remanded to LINA for proper consideration of her award of Social Security disability benefits.
Ms. Holt, the Plaintiff, previously received long-term disability benefits under an ERISA plan. Ms. Holt's benefits were terminated by LINA. After exhausting her administrative appeals, the Plaintiff ... filed suit in federal district court for the Eastern District of Tennessee, alleging that LINA's denial of benefits was arbitrary and capricious, and requesting that she be awarded the benefits denied. The decision to terminate Ms. Holt's benefits was based primarily on the opinions of non-treating, non-examining physicians, whose findings were contradicted by the opinions of Ms. Holt's own treating specialist - a rheumatologist. While Ms. Holt's claim for benefits was pending with LINA at the administrative level, she was approved for Social Security disability benefits. LINA never addressed Ms. Holt's approval for Social Security disability benefits, despite requiring that she apply for Social Security disability benefits, and despite having knowledge that Ms. Holt was awarded those benefits. In this case the district court found that LINA's failure to substantively consider Ms. Holt's approval for Social Security disability benefits, rendered its determination arbitrary and capricious.
