Unreported / Non-Citable
Background
Anna Bachand challenged Reliance Standard’s termination of long-term disability benefits under an employee benefit plan governed by ERISA. The court reviewed the administrative record and the plan’s definition of total disability, including treating-provider opinions, reported symptoms, and contemporaneous office notes.
The Court’s Holding
After a bench determination on the record, the court found for Reliance. It concluded that the treating opinions and subjective reports did not show functional limitations severe enough to establish inability to perform suitable work during the relevant period. Reliance was permitted to consider the lack of objective support and was not required to accept symptom reports at face value.
Key Takeaways
- Insurer prevails after claimant fails to prove total disability under an ERISA long-term disability plan.
- The ruling turns on the governing legal standard and the specific evidentiary record, not labels alone.
- Practitioners should preserve a clear, fact-linked record for review and remedy.
Why It Matters
In an ERISA case under de novo review, the claimant still bears the burden of proving entitlement under the plan’s actual terms. Practitioners should build contemporaneous records that translate diagnoses and symptoms into concrete occupational restrictions; later conclusory letters may carry little weight when office notes do not document comparable severity.