Erisa and Disability Benefits Law Blog

The claimant, Toni Dramse, worked for Delta Air Lines between 1984 and 2000.  She contacted Aetna Life Insurance Company in 2000 stating that she was suffering from the effects of her 1997 work-related injury.  The Administrative Committee of Delta Air Lines administered the Delta Family-Care Disability and Survivorship Plan.  The Committee delegated the initial disability decisions under the plan to Aetna.  Aetna initially authorized short-term disability benefits for Dramse for a few weeks.

In 2003, Dramse sought long-term disability benefits.  Aetna denied her request and provided Dramse with a 90-day appeal period.  Dramse appealed and submitted additional information.  Aetna reversed its denial in part, awarding additional short-term disability benefits but again denying long-term disability benefits.  Dramse appealed the denial of long-term disability benefits and submitted additional medical information.  Aetna reaffirmed its denial.  Dramse then appealed to the Committee, which upheld the denial of benefits.

In 2005, Dramse filed suit in federal district court under ERISA, seeking benefits, pre-judgment interest, attorneys’ fees, and a declaratory judgment.

The district court found that the plan conferred discretion on the Committee to interpret the plan, meaning that the court would review the benefits denial under an abuse of discretion standard.  After a lengthy analysis of the facts and medical evidence, the court concluded that the Committee abused its discretion in denying the claim.  The court stated: “The Committee’s factual finding that Plaintiff was not unable to work as of November 8, 2000, necessarily included a determination that Plaintiff was not physically or psychologically unable to work as of that date.  Although some record evidence supports a finding that Plaintiff was not physically unable to work as of November 8, 2000, Defendant has not cited to any record evidence that supports a finding that Plaintiff was not psychologically unable to work as of November 8, 2000, and there is significant contrary evidence.”  Therefore, as the court concluded, “Because the Committee’s conclusion that Plaintiff was not psychologically unable to work was not supported by the record evidence, the Court finds that the Committee abused its discretion.”

The court accordingly granted Dramse’s motion for summary judgment and ordered supplemental briefing regarding the proper remedy for the defendant’s abuse of discretion.  The cite is Dramse v. Delta Family-Care Disability and Survivorship Plan, 2006 WL 2371334 (N.D. Tex. Aug. 16, 2006).  Dramse was represented by Bernard A. Guerrini of Dallas, Texas.