Sanford v. Life Insurance
Plaintiff Edward Sanford filed an ERISA action against Life Insurance Company of North America (LINA) to contest the denial of his short- and long-term disability benefits. Sanford had voluntarily resigned from his employment on November 3, 2010, and sustained an injury on November 8, 2010. LINA denied his claim, asserting he was not an "eligible employee" or "in Active Service" at the time of the injury, despite having accrued paid time off. The District Court applied an arbitrary and capricious standard of review, concluding that LINA's decision was rational given the plan provisions and the administrative record, as Sanford was retired and not on a "scheduled vacation day" as per the policy definitions. The Court granted LINA's motion for judgment and denied Sanford's.