Eleventh Circuit January Update
Melech v. Life Ins. Co. of North America, et al. involved an employee’s welfare benefit plan provided by her employer, Hertz. Ms. Melech’s plan was administered by Life Insurance Company of North America (“LINA”), and governed by ERISA. Her employment with Hertz ended in May 2007, when she was taken off work by her treating physician due to degenerative disc disease. Ms. Melech then submitted a claim for long-term disability benefits under the policy, and SSA benefits. LINA denied her claim, and she appealed through an administrative process. SSA granted her application for benefits, and she informed LINA of the same. LINA continued to deny coverage. This litigation ensued, and Ms. Melech brought a ERISA action in October 2010, claiming LINA violated ERISA requirements, and especially due to their decision to ignore the SSA process/information. The District Court granted summary judgment in favor of LINA, finding that it made a decision based on the information it had at the time. The 11th Circuit agreed, in part, that LINA did not have the same information available to the SSA at the time of the last denial, and therefore vacated and remanded the case to LINA for consideration based on the new information. The Court noted that SSA produces more than just money, and their evaluation can be helpful to LINA. In fact, the Court found that LINA should have considered the evidence that was generated by SSA, because LINA plays an active role in SSA benefits. Therefore, the 11th Circuit remanded with instructions for LINA to make a decision regarding Melech’s claims with the “full benefit” of the information from the SSA investigation.