Reported / Citable
Background
Jasmine Gadelmola challenged Reliance Standard Life Insurance Company’s termination of her long-term disability benefits under an ERISA-governed policy. She sought to clarify and enforce her rights under the policy, arguing that the administrative record established that she remained disabled.
The parties filed cross-motions for judgment on the administrative record. Reliance Standard argued that substantial evidence supported its determination that Gadelmola was not totally disabled from any occupation and therefore was ineligible for benefits beginning April 8, 2022.
The Court’s Holding
Judge Charles Eskridge adopted Magistrate Judge Yvonne Y. Ho’s memorandum and recommendation, denied Gadelmola’s motion for judgment on the record, granted Reliance Standard’s motion, and affirmed the benefits denial from April 8, 2022 onward.
The court rejected Gadelmola’s objection to abuse-of-discretion review. Although she argued that discretionary language appeared only in the summary plan description rather than the policy, the court concluded that the policy contained the same relevant ambiguity addressed in Manuel v. Turner Industries Group, LLC. Under that precedent, the court could consult the summary plan description to resolve the ambiguity, making abuse-of-discretion review appropriate. The court found no clear error in the remaining recommendation and dismissed the action with prejudice.
Key Takeaways
- An ambiguous ERISA plan may permit consideration of the summary plan description to determine whether the administrator received discretionary authority.
- The court applied abuse-of-discretion review to Reliance Standard’s disability determination.
- Reliance Standard’s denial of long-term disability benefits from April 8, 2022 forward was affirmed.
Why It Matters
The order reinforces that, under Fifth Circuit precedent, a summary plan description can bear on the standard of review when the governing policy is ambiguous about administrative discretion. That determination can be dispositive in an ERISA benefits case because it limits review to whether the administrator abused its discretion rather than whether the claimant was disabled under a fresh de novo determination.