Connie Thacker v. Schneider Electric USA, Inc.

547 F. App'x 691
CourtCourt of Appeals for the Sixth Circuit
DecidedOctober 30, 2013
Docket13-5306
StatusUnpublished
Cited by1 cases

This text of 547 F. App'x 691 (Connie Thacker v. Schneider Electric USA, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Connie Thacker v. Schneider Electric USA, Inc., 547 F. App'x 691 (6th Cir. 2013).

Opinion

STAFFORD, District Judge.

The plaintiff-appellant, Connie Thacker (“Thacker”), filed this ERISA action after her former employer, Schneider Electric USA, Inc. (“Schneider”), denied her applications for disability retirement and disability life insurance benefits. The district court entered summary judgment for Schneider. On Thacker’s appeal from that judgment, we AFFIRM.

I. BACKGROUND

Schneider (f/k/a Square D Company) hired Thacker on June 22,1994, to work at a plant in Lexington, Kentucky. As a union employee, Thacker was eligible to participate in employee-sponsored benefit plans governed by the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. §§ 1001-1461, including the Square D Company Coordinated Bargaining Employees’ Pension Plan (the “Pension Plan”) and the Group Life and Health Plan for Coordinated Bargaining Employees (the “Life and Health Plan”). The Pension Plan is an “employee pension benefit plan” as defined in 29 U.S.C. § 1002(2). The Life and Health Plan is an “employee welfare benefit plan” as defined in 29 U.S.C. § 1002(1). At all relevant times, Schneider (or its predecessor, Square D Company) has been the plan sponsor for both the Pension Plan and the Life and Health Plan. The plan administrator for both plans is an administrative committee appointed by Schneider. Both plans grant broad discretion to the plan administrator to determine eligibility for benefits and to construe and interpret the terms of the respective plan documents.

Thacker began a disability leave of absence on June 8, 2008. After that date, she did not return to work or perform any of her job functions. On June 15, 2009, Thacker stopped paying the required premiums under the Life and Health Plan. She was advised in November 2009 that, in fact, her medical and life insurance coverage was cancelled retroactive to June 15, 2009, for non-payment of premiums.

On September 23, 2010, more than a year after she ceased being covered under the Life and Health Plan, Thacker applied to Schneider for both disability retirement benefits and disability life insurance benefits. Included with her applications was a copy of a letter from the Social Security Administration (“SSA”) dated September 16, 2010, advising Thacker that she was entitled to monthly disability benefits retroactive to June 1, 2009. 1 Her application for disability life insurance benefits was soon after denied based on her failure to submit proof — as required by the Life and Health Plan — of “Total and Permanent Disability” within one year after ceasing to be a covered individual. Her application *693 for disability retirement benefits was similarly denied for untimeliness.

After she unsuccessfully appealed the two decisions administratively, Thacker filed this action, seeking reversal of the plan administrator’s denial of her applications for benefits. The district court entered summary judgment for Schneider, finding — among other things — that the denial of Thacker’s applications for benefits was not arbitrary and capricious. This appeal followed.

II. STANDARD OF REVIEW

We review de novo a district court’s grant of summary judgment in an ERISA action, “applying the same standard of review to the administrator’s action as required by the district court.” Bidwell v. Univ. Med. Ctr., Inc., 685 F.3d 613, 616 (6th Cir.2012) (quoting Moore v. Lafayette Life Ins. Co., 458 F.3d 416, 427 (6th Cir. 2006)). Summary judgment is appropriate where the pleadings and affidavits show that there is no genuine issue of material fact and one party is entitled to judgment as a matter of law. Fed.R.Civ.P. 56(a). In an ERISA case, the relevant genuine issue of material fact is whether the administrator’s decision was appropriate in light of the applicable standard of review. Farhner v. United Transp. Union Discipline Income Prat. Program, 645 F.3d 338, 342 (6th Cir.2011).

ERISA does not specify the judicial standard of review applicable to actions challenging a plan administrator’s benefits determination. In Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 109 S.Ct. 948, 103 L.Ed.2d 80 (1989), however, the Supreme Court established that a denial of benefits “is to be reviewed under a de novo standard unless the benefit plan gives the administrator ... discretionary authority to determine eligibility for benefits or to construe the terms of the plan.” Id. at 115, 109 S.Ct. 948. When discretionary authority to determine eligibility for benefits or to construe the terms of a plan is granted to an ERISA plan administrator, the highly deferential arbitrary-and-capricious standard of review is appropriate. Judge v. Metro. Life Ins. Co., 710 F.3d 651, 657 (6th Cir.2013).

Here, the district court found — and Thacker does not dispute — that both the Pension Plan and the Life and Health Plan give the plan administrator discretionary authority to not only interpret the terms of the respective plans but also to determine eligibility for benefits under the plans. The district court accordingly determined — and we agree — that the arbitrary- and-capricious standard of review governs the issues in this case. The district court correctly rejected Thacker’s arguments for a less deferential standard of review based on the plan administrator’s purported bias. See id. at 664.

III. ANALYSIS

We review de novo a district court’s decision regarding the denial of benefits under an ERISA plan. Smith v. Cont'l Cas. Co., 450 F.3d 253, 258 (6th Cir.2006). Like the district court, we will not overturn an administrator’s discretionary decision to deny benefits unless that decision was arbitrary or capricious. An administrator’s decision is not arbitrary or capricious “if it is the result of a deliberate, principled reasoning process and if it is supported by substantial evidence.” Glenn v. MetLife, 461 F.3d 660, 666 (6th Cir.2006) (internal quotation marks omitted).

A. Disability Life Insurance Benefits

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Bluebook (online)
547 F. App'x 691, Counsel Stack Legal Research, https://law.counselstack.com/opinion/connie-thacker-v-schneider-electric-usa-inc-ca6-2013.