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Dwinnell v. Federal Express Long Term Disability Plan

United States District Court, D. Connecticut

March 9, 2016

JENNIFER DWINNELL, Plaintiff,
v.
FEDERAL EXPRESS LONG TERM DISABILITY PLAN, et al., Defendants

ORDER RE CROSS MOTIONS FOR PARTIAL SUMMARY JUDGMENT

Jeffrey Alker Meyer United States District Judge

Plaintiff Jennifer Dwinnell appeals from a denial of her claim for long term disability benefits under the terms of a disability plan furnished by her employer Federal Express Corporation. The parties have cross-moved for partial summary judgment with respect to what standard of review I should apply to adjudicate this claim. For the reasons set forth below, I conclude that I should apply an abuse-of-discretion standard of review rather than de novo review. Accordingly, I will deny plaintiff’s motion for summary judgment and grant defendant’s motion for summary judgment.

Background

Since at least 2006, Federal Express Corporation (FedEx) has offered a long term disability benefit plan for its employees. The FedEx plan (the Plan) is subject to the Employee Retirement Income Security Act of 1974 (ERISA), the enormously complex federal statute that governs employee benefit plans. See 29 U.S.C. 1001 et seq. As relevant here, the Plan sets forth detailed procedures for employees to file claims for disability benefits and also to appeal any adverse determination. See Doc. #22-7.

In July 2012, plaintiff Jennifer Dwinnell was denied disability benefits under the Plan. The specific grounds for denial of her claim are not presently relevant to the parties’ cross- motions for partial summary judgment. What matters for now is that plaintiff’s claim was denied at the first level of review by the Plan’s claims paying administrator and that this initial denial was then upheld on administrative appeal. At the time that plaintiff’s claim was considered, FedEx had retained Aetna Life Insurance Company (Aetna) to conduct both the initial claims determination as well as to conduct the administrative appeal of the denial of this claim.

Plaintiff has filed this federal court action to seek review of the denial of her disability claim. The parties have now cross-moved for partial summary judgment on a preliminary but perhaps outcome-determinative issue in this case: whether I should apply de novo review of the denial of plaintiff’s claim (as plaintiff argues) or whether I should conduct deferential, abuse-of-discretion review of the denial of plaintiff’s claim (as defendant argues).

In Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (1989), the Supreme Court made clear that when an ERISA claimant is denied benefits under his or her benefits plan, the claimant’s denial is subject to de novo review in a court challenge like this one “unless the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan, ” in which case the claimant’s denial is instead subject to deferential, abuse-of-discretion review. Id. at 115. Here, plaintiff claims that no deferential review should apply in this case because, according to plaintiff, Aetna was not properly appointed with fiduciary authority under the Plan to conduct the administrative appeal review of the denial of her claim.

A. Essential Roles and Provisions of the Plan

In order to understand plaintiff’s somewhat complex argument about why Aetna lacked fiduciary authority, it is necessary at the outset to review in some turgid detail the specific provisions and decision-making roles of several entities under the Plan. Insofar as relevant to this case, the Plan delegates key responsibilities to four different entities: (1) the Administrator, (2) the Committee, (3) the Claims Paying Administrator, and (4) the appeal committee. Each of these roles is described below.

1. The Administrator

The Plan designates FedEx as the Administrator, an entity charged with administering the Plan through its employee benefits department. Plan, § 1.1(a). Article 6 of the Plan provides that “[t]he Administrator is a named fiduciary of the Plan and shall have the absolute right and power to construe and interpret the provisions of the Plan and administer it for the best interest of Employees.” Plan, § 6.1. This interpretive power includes the ability “to construe any ambiguity and interpret any provision of the Plan or supply any omission or reconcile any inconsistencies in such manner as it deems proper.” Ibid. (emphasis added).

The Administrator also has authority “to determine eligibility for coverage under the Plan in accordance with its terms, ” as well as “to decide all questions of eligibility for, and determine the amount, manner and time of payment of, benefits under the Plan in accordance with its terms.” Plan, § 6.1(b)-(c). The Plan further provides that “[t]he determination of the Administrator shall be made in a fair and consistent manner in accordance with the Plan’s terms and its decision shall be final, subject only to a determination by a court of competent jurisdiction that the Administrator’s decision was arbitrary and capricious.” Plan, § 6.1.

2. The Committee

Notwithstanding that the FedEx company itself serves as the Plan’s Administrator, the Plan further provides for the appointment of what it calls “the Committee” by the FedEx Board of Directors “to perform the administrative duties hereunder” and to assume “general administrative power” over the Plan and “with such other powers as may be necessary to perform its duties hereunder, ” apart from the specific functions of claims administration (which are discussed below). See Plan, § 6.2 (describing functions of the Committee).[1] In addition to vesting “the Committee” with general administrative power, the Plan further provides that “[t]he Committee is a named fiduciary of the Plan.” Although the identity and composition of “the ...


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