Miller v. Wang Laboratories, Inc.

998 F. Supp. 78, 1998 U.S. Dist. LEXIS 3797, 1998 WL 148836
CourtDistrict Court, D. Massachusetts
DecidedMarch 24, 1998
DocketCivil Action No. 96-10831-MLW
StatusPublished
Cited by1 cases

This text of 998 F. Supp. 78 (Miller v. Wang Laboratories, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Miller v. Wang Laboratories, Inc., 998 F. Supp. 78, 1998 U.S. Dist. LEXIS 3797, 1998 WL 148836 (D. Mass. 1998).

Opinion

MEMORANDUM AND RULING ON STANDARD OF REVIEW TO BE APPLIED TO DISCONTINUANCE OF PLAINTIFF’S BENEFITS UNDER DEFENDANTS’ ERISA PLAN

■ COLLINGS, United States Magistrate Judge.

I. Introduction

Plaintiff Ruth Miller (“Miller”) filed.this action pursuant to the Employee Retirement Income and Security Act, 29 U.S.C. §§ 1001 et, seq. (“ERISA”), to challenge the termination of her. long-term disability benefits. The parties have agreed that their dispute can be decided by the Court on a stipulated record. The parties disagree, however, on what standard of review the Court should use in reviewing the record. In this memorandum, the Court considers Miller’s request that the Court employ a de novo standard in reviewing the decision by defendants to terminate her long-term disability benefits.

II. Facts and Procedural History

Miller was employed by defendant Wang Laboratories, Inc. (“Wang”) until she became totally disabled, by back pain in the Spring of 1986. At the time, Miller was, covered by an employer-sponsored long-term disability insurance policy issued, by defendant Metropolitan Life Insurance Company (“Met Life”), and she began receiving monthly benefits under that Plan. A Summary Plan Description provided by Met Life and in effect at the time Miller began receiving benefits (“the ’83 Plan”) stated as follows with regard to payment of benefits under the Plan:

When we receive proof of a claim, the Monthly Benefit will be paid to you.... All proof must be, satisfactory to us.

# 26, Exh. 2 at p. 14.

With regard to the procedure for filing a claim for long-term disability benefits, the Summary Plan Description stated:

[79]*79Proof [of a claim] must describe the event, the nature and the extent of the cause for which a claim is made; it must be satisfactory to us.

# 26, Exh. 2 at p. 16.

The Employee Handbook in effect at the time Miller began receiving benefits stated as follows:

The company has the exclusive right to interpret and administer the provisions of each plan, and its decisions are conclusive and binding.

# 18, Exh. 2 at p. 41.

In July 1994, Met Life informed Miller that her disability benefits would be discontinued because it no longer considered her to be disabled. Miller asked Met Life to reconsider that decision, and after review, it affirmed its initial decision. Pursuant to the Plan’s appeal process, Miller then asked the Plan Administrator to review Met Life’s decision. In January 1996, the Plan Administrator affirmed the decision to terminate her benefits. She filed this timely ERISA action, claiming defendants improperly denied her benefits to which she was entitled. See 29 U.S.C. § 1132(a)(1)(B) (authorizing cause of action by beneficiary to recover benefits due under the terms of the plan).

At some point between the time Met Life first informed Miller it was terminating her benefits and the time the Plan Administrator affirmed that decision, Wang amended its Long-Term Disability plan. The new Summary Plan Description (“the ’95 Plan”) stated:

The Plan Administrator has the exclusive right to interpret and administer the provisions of the plans in its sole discretion, including all questions relating to eligibility and entitlement to benefits, and its decision regarding any issue or appeal is conclusive and binding on all parties.

# 26, Exh. 1 at p. 129.

Miller argues that the ’83 Plan, not the ’95 Plan, applies to her ERISA claim, and that the ’83 Plan does not grant discretion to. the defendants to administer the Plan or to determine conclusively benefit . eligibility. Thus, she asserts that the Court should review the denial of her benefits de novo. The Court need not decide which Plan should apply, because even if the ’83 Plan applies, as plaintiff urges, the- Court may not employ a de novo standard, for the reasons which follow.

III. Analysis

In Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 109 S.Ct. 948, 103 L.Ed.2d 80 (1989), the Supreme Court announced the standard of review district courts should use in considering whether an ERISA plaintiff is entitled to relief under 29 U.S.C. .§ 1132(a)(1)(B)' for denial of benefits. The Court held that a de novo standard of review should be used “unless the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan.” Firestone, 489 U.S. at 115; see also Diaz v. Seafarers Int’l Union, 13 F.3d 454, 456 (1 Cir., 1994). Where the administrator or fiduciary is given the requisite discretion under the terms of the plan, the district court may only inquire as to whether the decision denying benefits was “arbitrary and capricious.” Firestone, 489 U.S. at 109-11.

Miller seems to concede that the ’95 Plan grants discretion to the Plan Administrator, so if that Plan were to apply, the Court would be bound to review the Plan Administrator’s decision under an “arbitrary and capricious” standard. But Miller contends that the ’83 Plan applies instead, and that that Plan does not confer the necessary discretion upon the Administrator or upon the fiduciary.

In order for the “arbitrary and capricious” standard to apply, it must be determined whether the requisite discretionary authority is expressly conferred by the plan. See, e.g., Moon v. American Home Assur. Co., 888 F.2d 86, 88-89 (11 Cir., 1989); Batchelor v. International Bhd. of Elec. Workers Local 861 Pension & Retirement Fund, 877 F.2d 441, 443 (5 Cir., 1989); Boyd v. Trustees of United Mine Workers Health & Retirement Funds, 873 F.2d 57, 59 (4 Cir., 1989); Bali v. Blue Cross & Blue Shield Ass’n, 873 F.2d 1043, 1047 (7 Cir., 1989). However, the plan need not use any particu[80]*80lar language in conferring discretion. Block v. Pitney Bowes, Inc., 952 F.2d 1450, 1453 (D.C.Cir.1992). Instead, any language which reasonably shows an intent to confer such power and discretion upon the Plan Administrator or on the fiduciary will be sufficient. Id.

In Donato v. Metropolitan Life Ins. Co., 19 F.3d 375

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Brigham v. Sun Life of Canada
183 F. Supp. 2d 427 (D. Massachusetts, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
998 F. Supp. 78, 1998 U.S. Dist. LEXIS 3797, 1998 WL 148836, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miller-v-wang-laboratories-inc-mad-1998.