Unum Life Prevails in ERISA Disability Case
In Poniewierski v. Unum Life Assurance Company of America, 2006 WL 2385045 (E.D. Mich. Aug. 17, 2006), an ERISA disability lawsuit, the federal district court held in favor of the insurance carrier, Unum Life. The plaintiff, Mark Poniewierski, sustained injuries at work while attempting to lift steel pieces. Unum Life denied his claim for short-term disability benefits, finding that the short-term disability plan did not cover injuries caused by work-related injuries. Poniewierski filed suit against Unum Life, arguing that he was entitled to long-term disability benefits and that Unum acted arbitrarily and capriciously in treating his claim as one for short-term disability benefits. Applying a de novo standard of review (due to the lack of any language granting discretionary authority to Unum Life), the court upheld Unum Life’s denial of benefits. The court found that there was no evidence that Poniewierski had ever filed a claim for long-term disability benefits. The court concluded that Unum Life’s decision to construe his application “as one for STD benefits was correct because the overwhelming weight of the evidence in the record indicates that Poniewierski filed for benefits under the STD policy” instead of the separate long-term disability plan. Next, the court ruled that Unum Life’s denial of benefits was supported by the record. Among other things, the court stated that the record showed that his injury was work-related and that such injuries were not covered by the short-term disability plan. Finally, the court held that Poniewierski had failed to exhaust his administrative remedies (by failing to appeal Unum Life’s denial before filing suit) and had missed the applicable statute of limitations period.