United States District Court, M.D. Tennessee, Nashville Division
WILLIAM J. HAYNES, Jr., District Judge.
Plaintiff, Gene Gamble, filed this action under the Employee Retirement Income Security Act ("ERISA"), 29 U.S.C. § 1001 et seq. seeking an award of long term disability benefits ("LTD") from Defendant, Prudential Disability Insurance Company, the administrator of Plaintiff's employee benefits plan. The Defendant filed the Administrative Record. (Docket Entry No. 20, Attachments 4-7).
Before the Court is Defendant's motion for summary judgment (Docket Entry No. 20), contending, in sum, that Plaintiff's benefits were limited to a 15-month term that Defendant paid and Plaintiff is not entitled to further benefits under the Plan. Defendant also asserts that Plaintiff's state law claims are preempted under ERISA. Plaintiff has not filed a response to Defendant's motion for summary judgment.
For the reasons set forth below, the Court concludes that based upon the undisputed facts Defendant's motion for summary judgment should be granted.
A. Findings of Fact
Plaintiff worked as a vice president for JP Morgan Chase Bank, N.A. ("JP Morgan"). (Docket Entry No. 20-9, Defendant's Statement of Material Facts, at ¶ 10). Plaintiff participated in the JP Morgan Chase Long-Term Disability Plan ("the Plan") that provides certain disability insurance benefits to eligible employees. Id. at ¶ 1. Prudential Disability Insurance Company ("Prudential") is the claims administrator of the Plan. Id. at ¶¶ 1-2. On August 15, 2011, Plaintiff, who was 68 years old, discontinued his employment because of a serious medical condition. Id. at ¶¶ 11-12; Docket Entry No. 1-1, Complaint, at ¶ 4. Plaintiff applied for long term disability ("LTD") benefits from the Plan in December 2011. (Docket Entry No. 20-9, Defendant's Statement of Material Facts, at ¶ 13).
According to the terms of the Plan, an employee who is 68 years old on the date disability begins, will receive LTD benefits for a maximum duration of 15 months. (Docket Entry No. 20-4, Administrative Record at 22-23). On January 13, 2012, Plaintiff's claim for LTD benefits was approved. (Docket Entry No. 20-7, Administrative Record at 218-220. Defendant stated, "LTD benefits are approved to the maximum duration date of May 12, 2013." Id. at 218. Plaintiff began receiving benefits on February 13, 2012, and these benefits were terminated on May 12, 2013. (Docket Entry No. 20-9, Defendant's Statement of Material Facts, at ¶ 16). In a letter dated January 11, 2013, Defendant informed Plaintiff of the following:
Under the terms of the plan, benefits are payable up to a maximum duration, and our records indicate that the maximum duration of your LTD claim is May 12, 2013. Therefore, your claim is terminated effective May 13, 2013 with no further benefits payable.
Please note that your claim is not being closed on the basis of an evaluation of your medical status but rather on the contractual maximum duration of benefits payable under the terms of the policy.
(Docket Entry No. 20-7, Administrative Record at 214). Plaintiff twice appealed the termination of LTD benefits, but Defendant denied his appeals, explaining that under the terms of the Plan, Plaintiff was only allowed to receive 15 months of LTD benefits. (Docket Entry No. 20-9, Defendant's Statement of Material Facts at ¶¶ 17-20; Docket Entry No. 20-7, Administrative Record at 208-215).
B. Conclusions of Law
Under ERISA, the review of a denial of benefits is subject to a "de novo standard unless the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan." Firestone Tire Rubber Co. v. Bruch, 489 U.S. 101, 115 (1989). If the language of the Plan grants the plan administrator discretionary authority to determine eligibility for benefits or to construe plan terms, then the arbitrary and capricious standard applies. Id.; Yeager v. Reliance Standard Life Ins. Co., 88 F.3d 376, 380 (6th Cir. 1996). For the arbitrary and capricious standard of review, the Plan must contain "a clear grant of discretion [to the administrator] to determine benefits or interpret the plan.'" Perez v. Aetna Life Ins. Co., 150 F.3d 550, 555 (6th Cir. 1998) (en banc) (quoting Wulf v. Quantum Chem. Corp., 26 F.3d 1368, 1373 (6th Cir. 1994) (emphasis in original).
Here, the Plan grants Prudential discretion to interpret the terms of the Plan and determine eligibility for benefits. Under the terms of the Plan,
The Prudential Insurance Company of America as Claims Administrator has the sole discretion to interpret the terms of the Group Contract, to make factual findings, and to determine eligibility for benefits. The decision of the Claims ...