In Richardson v. Foundation of Health, 2006 WL 2524176 (D.N.J. Aug. 30, 2006), a federal court in New Jersey upheld an ERISA plan’s termination of benefits. The claimant, Ann Richardson, applied for long-term disability benefits after a car wreck. Her treating physicians diagnosed her with herniated discs at the C3-C4 and C5-C6 levels, radiculopathy, post-traumatic carpal tunnel syndrome, and other problems. The plan, in turn, obtained reports from three physicians who examined Richardson for purposes of the claim. The plan discontinued benefits after receiving the reports from these evaluating physicians.
Richardson appealed the termination of benefits, but did not submit additional information as part of the appeal. The plan denied her appeal, stating that the “duration of symptoms without objective evidence to support them does not support the inability to function at a sedentary level occupation.” The plan later reopened the claim when Richardson submitted information that her vision has worsened as a result of diabetic retinopathy and macular edema. She also submitted additional evidence regarding her spinal condition, including an MRI that showed central spinal stenosis and bilateral spondyloarthritis. The plan continued to deny benefits, concluding that there was no objective proof of functional limitations.
Richardson also received an award of Social Security disability benefits. After receiving evidence of the award, the plan sent Richardson’s claim file to the Medical Review Institute, which concluded that the records did not show that Richardson was unable to perform her prior job.
Richardson filed suit in a New Jersey state court. The plan defendants removed the case to federal district court under ERISA. Applying the arbitrary and capricious standard of review, the district court held as follows:
After its review of the record, the Court is unable to conclude that Defendants' decision was unreasonable or unsupported by the record. Defendants complied with the terms of their policy, considered each of Plaintiff's submissions appealing their decision, and gave reasons for their findings based on evidence in the record. Defendants were not bound by the opinion of Plaintiff's treating physician. Black & Decker Disability Plan v. Nord, 538 U.S. 822, 825 (2003) (holding “that plan administrators are not obliged to accord special deference to the opinions of treating physicians”). Nor were Defendants bound by the determination of the Social Security Administration. Russell v. Paul Revere Life Ins. Co., 148 F.Supp.2d 392, 409 (D.Del.2001) (noting that a “plan administrator is in no way bound by the determination of the Social Security Administration”). As a result, the Court grants summary judgment to Defendants.
