Although Not Unanimous Or Conclusive, Several Professional Opinions and Significant Evidence Supporting A Plan Administrator's Decision To Terminate Benefits Is Adequate Support To Affirm
JENKINS v. PRICE WATERHOUSE LONG TERM DISABILITY PLAN (May 4, 2009)
Charles Jenkins went to work for PricewaterhouseCoopers LLP ("PwC") in 1989. He started experiencing health problems related to HIV in 1993. He suffered from fatigue, nerve damage, decreased sensation, dexterity limitations, and infections. By the end of 1993, he was no longer able to work. He filed a claim under PwC’s long-term disability plan. The plan administrator agreed that he met the definition of "total disability" and paid him benefits from 1994 until 2006. Beginning in 2004, the plan administrator began to review Jenkins' file. After two medical record reviews and an independent medical examination, the plan administrator terminated Jenkins' benefits. The more recent reviews concluded that Jenkins' condition was fairly stable and that he may be capable of performing some jobs. In fact, a rehabilitation specialist identified certain specific positions that fit within Jenkins’ limitations. Jenkins' treating physician disagreed with the conclusion and maintained that he was unable to work. After an unsuccessful internal appeal, Jenkins brought an action under ERISA. The district court granted summary judgment to the plan. Jenkins appeals.
In their opinion, Chief Judge Easterbrook and Judges Kanne and Evans affirmed. The Court noted that its review is highly deferential and looks only for "rational support" in the record. The Court found that support. Admittedly, the opinion was not unanimous, the evidence was not conclusive, and the result was not required. However, four medical professionals and significant medical evidence supported the plan's determination. That support was enough to affirm the judgment for the plan.
