Posted by: Melville Johnson, P.C.
May 12, 2008
Topic: Erisa Retirement Benefits
The Attorney's with Melville Johnson, P.C. can provide representation for you in cases involving Long Term Disability Benefits Appeals:
The United States Court of Appeals for the 11th Circuit in Byars v. Coca-Cola Co., 517 F.3d 1256, examined the "Own Occupation" and "Any Occupation" Standards in this Long Term Disability (LTD) Benefits appeal. Lisa Byars was an employee of Coca-Cola for twenty-three years when she was injured while vacationing out of the country. Unable to continue her work, Ms. Byars applied for short term disability pay and received six months of short-term disability pay. Thereafter, Ms. Byars filed a claim with Coca-Cola for LTD benefits. At the time of Ms. Byar's LTD request, Coca Cola's LTD plan was governed by ERISA and was administrated by ReliaStar.
The LTD plan provided benefits to disabled participants under two different definitions. Under the "own occupation" definition, a participant was eligible for benefits if, during the first 24 months following the disability, the injury prevented the individual from performing the normal duties of his or her actual job. Under the "any occupation" definition, a person was eligible for LTD benefits if, after the first 24 months of disability, the individual was unable to engage in any occupation for which she was qualified.
The District Court held that the denial was arbitrary and capricious under the "own occupation" standard and granted Ms. Byars LTD benefits for 24 months. The Court also held that Ms. Byars would not qualify for "any occupation" benefits, after the first 24 months, even though at the time Ms. Byars had not yet been disabled for the 24-month period. Ms. Byars appealed.
The Eleventh Circuit first examined the "own occupation" benefits standard, which compensated employees 60% of their average compensation. Because the trial court granted benefits below 60% and did not explain its rationale, the Circuit Court vacated the District Court's judgment and remanded for the lower court to address the issue of the amount of "own occupation" LTD compensation due to Ms. Byars.
The Court of Appeals also held that the District Court erred in its judgment on "any occupation" benefits. Because neither party raised the issue of "any occupation" benefits at the trial court level, because Ms. Byars had not yet been disabled for 24 months, and because the trial court did not give notice of its intent to address the issue on summary judgment, the holding could not stand. Therefore, this issue was also remanded. Lastly, the Court of Appeals upheld the trial court's decision to deny Ms. Byars attorney's fees, retroactive benefits and prejudgment interest. The Law Firm of Melville Johnson, P.C. is experienced in representing similar client's in private disability benefits appeals.
The information in this article was primarily derived from The Judicial View, A Publication of Vianello Forensic Consulting, LLC.
