Peterson v. Continental Casualty Co.
Peterson sued Continental Casualty Company (CNA) seeking short- and long-term disability benefits under ERISA. CNA denied the claims, arguing Peterson was not disabled from a modified, sedentary desk job CBS assigned him after his injury. Peterson cross-moved for summary judgment and sought to add CBS as a defendant for failing to provide plan documents. The court denied both summary judgment motions, finding CNA's interpretation of Peterson's 'regular occupation' as the temporary desk job to be arbitrary and capricious. The court remanded both disability claims to the Claim Administrator to re-evaluate based on Peterson's actual regular occupation prior to his injury, noting that an 'accommodation' job is not the 'regular occupation'. Peterson's request to amend the complaint to add CBS was also denied due to lack of demonstrated prejudice and insufficient grounds for ERISA sanctions.