Berg v. Lincoln National Life Insurance Company

CourtDistrict Court, E.D. Washington
DecidedJanuary 21, 2025
Docket2:24-cv-00097
StatusUnknown

This text of Berg v. Lincoln National Life Insurance Company (Berg v. Lincoln National Life Insurance Company) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Berg v. Lincoln National Life Insurance Company, (E.D. Wash. 2025).

Opinion

1 2 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 3 Jan 21, 2025 4 SEAN F. MCAVOY, CLERK 5 UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF WASHINGTON 7 8 BARBARA BERG, No. 2:24-CV-00097-SAB 9 Plaintiff, 10 v. FINDINGS OF FACT AND 11 THE LINCOLN NATIONAL LIFE CONCLUSIONS OF LAW 12 INSURANCE COMPANY, 13 Defendant. 14 15 16 17 On December 12, 2024, the Court held a motion hearing in this matter in 18 Spokane, Washington. Plaintiff was represented by Robert Rosati. Defendant was 19 represented by Kristina Holmstrom. 20 At the hearing, the Court considered Plaintiff’s Motion for Declaratory 21 Judgment, ECF No. 27. This action is brought under Section 502(a) of the 22 Employee Retirement Income Security Act (“ERISA”), 29 U.S.C. § 1132(a), and 23 asks the Court to review de novo the administrative record regarding Plaintiff’s 24 entitlement to benefits. 25 After reviewing the briefs, administrative record, caselaw, and considering 26 the oral arguments, the Court finds Plaintiff is disabled and cannot perform any 27 occupation as defined by Defendant’s policy, which qualifies her for long term 28 benefits. As such, the Court grants Plaintiff’s motion. 1 STANDARD OF REVIEW 2 ERISA, 29 U.S.C. § 1001 et seq., was “enacted to promote the interests of 3 employees and their beneficiaries in employee benefit plans and to protect 4 contractually defined benefits.” Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 5 101, 113 (1989) (citations omitted). The Ninth Circuit has “repeatedly stated that 6 ERISA is remedial legislation that should be construed liberally to protect 7 participants in employee benefit plans.” LeGras v. AETNA Life Ins. Co., 786 F.3d 8 1233, 1236 (9th Cir. 2015) (citations omitted). 9 Under Section 502(a) of ERISA, 29 U.S.C. § 1132(a)(1): 10 A civil action may be brought— 11

12 (1) by a participant or beneficiary—

13 (A) for the relief provided for in subsection (c) of this 14 section, or

15 (B) to recover benefits due to him under the terms of his 16 plan, to enforce his rights under the terms of the plan, or to clarify his rights to future benefits under the terms of 17 the plan; 18 19 Every ERISA employee benefit plan shall “provide adequate notice in 20 writing to any participant or beneficiary whose claim for benefits under the plan 21 has been denied, setting forth the specific reasons for such denial, written in a 22 manner calculated to be understood by the participant.” 29 U.S.C. § 1133(1). To 23 start, the claim denial must contain, under 29 C.F.R. § 2560.503–1(g)(1): 24 (i) The specific reason or reasons for the adverse determination; 25

26 (ii) Reference to the specific plan provisions on which the determination is based; 27

28 1 (iii) A description of any additional material or information necessary for the claimant to perfect the claim and an explanation of why such 2 material or information is necessary; 3 (iv) A description of the plan's review procedures and the time limits 4 applicable to such procedures, including a statement of the claimant's right to bring a civil action under section 502(a) of the Act following 5 an adverse benefit determination on review; 6

7 For an adverse determination based on a group health plan, the denial must 8 also contain the internal rule, guideline or protocol followed, or an explanation of 9 the scientific or clinical judgment. See id. For an adverse determination based on 10 disability benefits, the denial must contain a discussion of the basis for disagreeing 11 with: 12

13 (i) The views presented by the claimant to the plan of health care professionals treating the claimant and vocational professionals who 14 evaluated the claimant; 15 (ii) The views of medical or vocational experts whose advice was 16 obtained on behalf of the plan in connection with a claimant's adverse 17 benefit determination, without regard to whether the advice was relied 18 upon in making the benefit determination; and

19 (iii) A disability determination regarding the claimant presented by the 20 claimant to the plan made by the Social Security Administration; 21 22 See id. After denial, the claimant is entitled to a “full and fair review” from 23 the plan administrator on appeal. 29 U.S.C. § 1133(2); 29 C.F.R. § 2560.503– 24 1(h)(4). If the plan administrator denies the appeal, then claimant may seek review 25 in federal court. 29 U.S.C. § 1132(a)(1)(B). 26 District courts review the administrative record and ERISA benefits claims 27 de novo. See Collier v. Lincon Life Assurance Co. of Boston, 53 F.4th 1180, 1182 28 (9th Cir. 2022). An ERISA review is done through a bench trial on the 1 administrative record. See Kearney v. Standard Ins. Co., 175 F.3d 1084, 1094–95 2 (9th Cir. 1999) (en banc). The administrator’s conclusions do not receive 3 deference. See Abatie v. Alta Health & Life Ins. Co., 458 F.3d 955, 963 (9th Cir. 4 2006) (en banc). However, “the district court must examine only the rationales the 5 plan administrator relied on in denying benefits and cannot adopt new rationales 6 that the claimant had no opportunity to respond to during the administrative 7 process.” Collier, 53 F.4th at 1182. 8 The Ninth Circuit disapproves of new arguments made by a plan 9 administrator during litigation, which protects the plaintiff claimant from being 10 “sandbagged” with a new review. Harlick v. Blue Shield of California, 686 F.3d 11 699, 719–21 (9th Cir. 2012); see also Wolf v. Life Ins. Co. of N. Am., 46 F.4th 979, 12 982 (9th Cir. 2022). But the plaintiff still bears the burden of proof. See Muniz v. 13 Amec Const. Mgmt., 623 F.3d 1290, 1294 (9th Cir. 2010). 14 Fed. R. Civ. P. 52(a) requires a court issue findings of fact and conclusions 15 of law for an ERISA review. If a district court finds a plan administrator has acted 16 arbitrarily or capricious in denying a claim for benefits, the court can either (1) 17 remand to the plan administrator for a renewed evaluation, or (2) award a 18 retroactive reinstatement of benefits. See Demer, 835 F.3d at 907. A retroactive 19 award of benefits must be supported by the administrative record. See id. 20 SUMMARY OF THE ADMINISTRATIVE RECORD 21 This case was filed in U.S. District Court for the Eastern District of 22 Washington on March 27, 2024. Pursuant to ERISA, 29 U.S.C. § 1132(a)(1), 23 Plaintiff claims Defendant wrongfully denied her long-term disability (“LTD”) 24 benefits under her Group Disability Income Policy (“the Policy”) issued to her as 25 an employee of Walmart Inc. and member of the Walmart Inc.

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Berg v. Lincoln National Life Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/berg-v-lincoln-national-life-insurance-company-waed-2025.