O'Quinn v. Trustees of the United Mine Workers Health & Retirement Funds

207 F. App'x 288
CourtCourt of Appeals for the Fourth Circuit
DecidedNovember 28, 2006
Docket05-2339
StatusUnpublished

This text of 207 F. App'x 288 (O'Quinn v. Trustees of the United Mine Workers Health & Retirement Funds) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
O'Quinn v. Trustees of the United Mine Workers Health & Retirement Funds, 207 F. App'x 288 (4th Cir. 2006).

Opinion

PER CURIAM:

The Trustees of the United Mine Workers Health & Retirement Funds (Trastees) appeal a district court order summarily reversing their denial of Ralph O’Quinn’s claim for disability benefits under the United Mine Workers of America 1974 Pension Plan (Plan). Because the Trustees did not abuse their discretion in deny *289 ing O’Quinn’s claim, we reverse and remand with instructions to enter summary-judgment in favor of the Trustees.

I.

O’Quinn, a former miner for Clinchfield Coal Company (Clinchfield), injured his back in January 2001 while attempting to exit a mantrip and move through a mantrap door. 1 An administrative law judge later found that O’Quinn was disabled due to his injury, and O’Quinn was awarded social security disability benefits.

O’Quinn separately applied for disability pension benefits under the Plan. The Trustees denied O’Quinn’s application on the ground that his disability was not caused by a “mine accident” as required by the Plan. J.A. 201. O’Quinn sought administrative review of this decision and submitted additional evidence in support of his claim. After a hearing, the Trustees upheld the denial of disability benefits. Relying on a rule interpreting the Plan, the Trustees concluded that O’Quinn’s disability did not result from a “mine accident” because it “was not caused by the exertion or impact of some external physical force or object against [O’Quinn’s] body or by the exertion or impact of [his] body against some external physical object.” Id. at 19.

O’Quinn later brought this action alleging that the Trustees improperly denied his claim for disability benefits. Both O’Quinn and the Trustees moved for summary judgment. The district court held that the Trustees had abused their discretion in denying O’Quinn’s claim. The court determined that O’Quinn’s disability was caused by a “mine accident,” concluding that “there was force and impact exerted on O’Quinn’s body”:

0’Quinn[ ] was not just simply bending over into a crouched position. [He] bent over, squatted, fell to his knees and turned all in the same motion and was in the process of pulling himself through the mantrap door when he was injured. Falling to one’s knees and pulling oneself through a door is an exertion of the body against some external physical object as required by Q & A 252, and, thus, any disabling injury suffered thereof, is the result of a mine accident.

O’Quinn v. Trs., UMWA Health & Ret. Fund, 395 F.Supp.2d 387, 391 (WD.Va.2005) . Accordingly, the district court granted O’Quinn’s summary judgment motion and denied the Trustees’ motion.

II.

The Trustees contend that the district court erred in reversing their denial of disability benefits to O’Quinn. We review the district court decision de novo. See Donovan v. Eaton Corp., Long Term Disability Plan, 462 F.3d 321, 326 (4th Cir.2006) . When, as here, an ERISA disability pension plan commits eligibility decisions to the discretion of the plan administrator, we review those decisions for abuse of discretion. See McCoy v. Holland, 364 F.3d 166, 169-70 (4th Cir.2004). In so doing, “we will not disturb such a decision if it is reasonable.” Booth v. Wal-Mart Stores, Inc. Assocs. Health & Welfare Plan, 201 F.3d 335, 342 (4th Cir.2000). While we may consider a variety of factors in assessing whether a plan administrator’s decision is reasonable, see id. at 342-43, the only factor seriously in question here is whether the evidence considered by the Trustees supports their decision, see McCoy, 364 F.3d at 170. Thus, “the Trus *290 tees’ decision is reasonable if it is supported by substantial evidence.” Id.

Under the Plan, a miner is eligible for a disability pension if, inter alia, he “becomes totally disabled as a result of a mine accident.” J.A. 236. Although the Plan does not define “mine accident,” an interpretive rule adopted by the Trustees, “Q & A 252,” imposes three requirements for determining that a miner is “disabled as [a] result of a mine accident”:

(1) Unexpectedness: The disability must have been unlooked for and unforeseen;
(2) Definiteness: The disability must be traceable to a definite time, place and occasion which occurred within the course of the mine worker’s employment ....;
(3) Force or impact: The disability must have been caused by the exertion or impact of some external physical force or object against the body or by the exertion or impact of the body against some external physical object; i.e., not simply as a result of the mine worker’s own physical condition.

Id. at 277 (internal quotation marks omitted; final emphasis added). 2 Here, the Trustees contest only the third requirement, maintaining that O’Quinn’s injury was not caused by a “[fjorce or impact” within the meaning of Q & A 252. The Trustees contend that substantial evidence supports their determination that the injury involved neither an external force or impact against O’Quinn’s body nor an exertion or impact of his body against an external object. We agree.

Clinchfield’s accident report on O’Quinn’s injury mentions no external force or impact involving O’Quinn’s body. That report states that O’Quinn “got out of [a] mantrip, bent forward and turned to go through [a] man door and felt something pull in his back.” Id. at 21. Nor do O’Quinn’s medical records describe an external force or impact in connection with the injury. For example, a record based on an examination of O’Quinn the day after the incident describes the injury as follows: “[O’Quinn] was getting out of a man-trip to check a gas meter. He was trying to squat and turn at the same time on the left side. At that time, he heard a snapping noise in his low back area.” Id. at 147. Other medical records similarly describe the injury without mentioning an external force or impact. See id. at 83 (stating that O’Quinn “got out of a mantrip backwards,” “[b]ent over, squatted, and turned all at the same time to go through a mandoor,” and “felt something move in his back”); id. at 142 (“[O’Quinn] states that as he was going into the mines ..., having parked his man-trip, [he] turned to get out of the man-trip, and ... felt ‘something *291 move in [his] lower back.’”); id. at 158 (“[O’Quinn] had ridden a mantrip into a section, and on getting out of it ... he backed out, turned and squatted at the same time to get low enough to go through a man door.

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Related

Vance v. Holland
22 F. Supp. 2d 529 (W.D. Virginia, 1998)
O'Quinn v. Trustees, UMWA Health & Retirement Fund
395 F. Supp. 2d 387 (W.D. Virginia, 2005)
Allen v. Holland
36 F. Supp. 2d 325 (S.D. West Virginia, 1997)

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Bluebook (online)
207 F. App'x 288, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oquinn-v-trustees-of-the-united-mine-workers-health-retirement-funds-ca4-2006.