Eighth Circuit Upholds Termination of Benefits in ERISA Suit
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Eighth Circuit Upholds Termination of Benefits in ERISA Suit

Lisa Gerhardt worked as the Director of Addiction Services for Bridgeway, Inc., which was owned and operated by Universal Health Services.  Universal Health provided long-term disability coverage to its employees under a policy issued by Liberty Life Assurance Company of Boston.  Gerhardt stopped working because she suffered from osteoarthritis and had to undergo surgery.  Gerhardt filed a claim for long-term disability benefits with Liberty.  In order to receive long-term disability benefits, the Policy required insured employees to provide Liberty with proof of disability.  The policy stated that the initial determination of whether an employee is “disabled” depends upon whether the employee is able to perform his or her own occupation.  After the employee has received benefits for twenty-four months, the determination depends upon whether the employee can perform his or her own occupation or any occupation for which the employee is reasonably fitted.  Liberty approved Gerhardt’s claim under the first standard and paid her long-term disability benefits in 2000.  In 2004 and 2005, Gerhardt’s claim was reevaluated and it was determined that she was capable of performing full-time work despite her medical conditions.  Liberty concluded that Gerhardt was no longer eligible for disability benefits and terminated her benefits.   Gerhardt sought judicial review of Liberty’s adverse benefits determination under ERISA.  The district court affirmed Liberty’s termination of long-term disability benefits.  The Eighth Circuit affirmed, concluding the record reflects that Liberty’s decision to terminate benefits was supported by substantial evidence and did not constitute an abuse of discretion.

Gerhardt v. Liberty Life Assurance Company of Boston, No. 12-3159 (8th Cir. Nov. 29, 2013). 

Gerhardt v Liberty Life Assur. Co. of Boston.pdf

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