What language is needed in the ERISA plan to confer discretion? 

The bar was just raised in the 4th Circuit.

Here’s the case of Cosey v. Prudential Insurance Company of America, [PDF] __F.3d__ (November 12, 2013).

FACTS:  Cosey was a marketing manager, eligible for short and long term disability (LTD) benefits under the company ERISA plan.  The LTD plan, administered by Prudential, stated that benefits will be paid only if the claimant “submit[s] proof of continuing disability satisfactory to Prudential” (emphasis added).

ISSUE:  Does the language confer discretion, or does the de novo standard of review apply?

4th CIRCUIT HELDDe novo review applies—the language did not confer discretion.

  1. “[F]ive of our sister circuits recently have held that this language does not unambiguously confer discretionary authority…. We agree with the conclusions reached by the five sister circuits.”  Op. at 7.
  2. “[T]he phrase ‘proof satisfactory to us’ is inherently ambiguous. Op. at 7-8
  3. The phrase does not clearly confer discretion because “such a construction…would not be an insured employee’s ‘most likely’ interpretation of that language.”  Op. at 8.
  4. [A]mbiguities in an ERISA plan must be construed against the administrator responsible for drafting the plan.”  Op. at 9.
  5. The court sidesteps language in Gallagher v. Reliance Standard, 305 F.3d 264, 268, 269 (4th Cir. 2002).  There, the 4th Circuit stated that plan language requiring that a claimant submit “proof…that is satisfactory to [the plan administrator]would “occasion abuse of discretion review.” But in this case the 4th Circuit stated the language in Gallagher was “dictum and does not bind our consideration of the plan language before us.” Op. at 7.
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Photo of Mike Reilly Mike Reilly

Mike Reilly is a nationally recognized labor, employment and employee benefits attorney, named one of the “Top 100 Most Powerful Employment Attorneys in the Nation” for the past five consecutive years by Human Resource Executive®. He has decades of experience providing strategic employment…

Mike Reilly is a nationally recognized labor, employment and employee benefits attorney, named one of the “Top 100 Most Powerful Employment Attorneys in the Nation” for the past five consecutive years by Human Resource Executive®. He has decades of experience providing strategic employment advice, and has represented clients in more than 75 jury trials, arbitrations, bench trials and claims before the EEOC and Washington State Human Rights Commission.

Small and large employers retain Mike for his strategic advice and decades of experience in employment issues and litigation, business decisions and litigation avoidance. Mike provides advice in claims involving discrimination, retaliation, wrongful discharge, disability accommodation, ERISA and non-ERISA employee benefit claims, and wage/hour claims. He served as lead counsel in an employee raiding/trade secret case as reported in the Wall Street Journal, and defends employers in class action claims.

Mike’s remarks on employment issues have been quoted in NewsweekCorporate Legal TimesSeattle TimesEmployee Relations Law JournalPuget Sound Business JournalCFO.com, and other professional journals and management publications. Chambers USA’s Guide to America’s Leading Lawyers for Businessrates Mike in the top ranking (band one) for his work in labor and employment law, and has described him as “one of Seattle’s top-rate attorneys” who is “truly phenomenal [with] superb legal instincts” and “an amazingly assertive litigator.” His clients include Nordstrom, Seattle Seahawks, Home Depot, KeyBank, Starbucks, Fred Hutchinson Cancer Research Center, Red Robin and Seattle Chamber of Commerce, among others.