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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Smith v. Bayer Corp. Long Term Disability Plan

Plaintiff Terry Smith, a former Diabetes Sales Specialist for Bayer Corporation, filed an action under ERISA to recover long-term disability benefits, claiming wrongful denial due to psychiatric impairments including depression, panic disorder, and bi-polar disorder. The Plan administrator, Bayer, upheld the denial based on reviews by non-examining physicians. However, Smith's treating psychiatrists, Dr. LeBuffe and Dr. McCool, consistently found him disabled. The court found the Plan's reliance on non-examining doctors, who 'cherry-picked' medical records and distorted findings, to be arbitrary and capricious. Consequently, the court granted Smith's motion for benefits, denying Bayer's, and also awarded partial disability benefits, ruling that Smith's failure to seek rehabilitation approval was excused by the prior wrongful denial.

ERISALong-term disabilityDisability benefits denialPsychiatric impairmentDepressionPanic disorderBi-polar disorderAttention Deficit Disorder (ADD)Treating physician ruleArbitrary and capricious standard
References
26
Case No. MISSING
Regular Panel Decision

Martin v. General Dynamics Long Term Disability Benefits Plan

Thomas E. Martin, a former General Dynamics employee, filed a lawsuit under ERISA against General Dynamics Long Term Disability Plan, General Dynamics Corporation, and Aetna Life Insurance Company. Martin claimed improper calculation of his long-term disability (LTD) benefits, arguing that the defendants wrongly deducted his workers' compensation and Social Security benefits. The central issue was the commencement date of Martin's total disability, as the Plan's terms allowed deductions if these other benefits were not received immediately prior to disability onset. The court, applying an abuse of discretion standard, determined that the defendants' decision to set Martin's disability onset date as May 10, 1990, the day he ceased working, was not arbitrary or capricious. This finding supported the defendants' deductions. Consequently, the court granted the defendants' motion for summary judgment and dismissed Martin's claims. An earlier motion by Lockheed Corporation was denied as moot.

Summary judgmentERISALong term disability benefitsBenefit calculationDisability onset dateAbuse of discretion standardFederal courtPlan interpretationEmployee benefitsDisability insurance
References
7
Case No. MISSING
Regular Panel Decision

Cantrell v. Electric Power Board

This worker's compensation case concerns an appeal by an employer, Nashville Electric Service (NES), challenging the Chancellor's denial of a set-off for supplemental short-term disability benefits against a permanent partial disability award. The employee, Jeffery L. Cantrell, sustained a work-related injury causing severe dermatitis, leading to 177.5 days of missed work and a subsequent transfer to a lower-paying position. NES sought to offset excess short-term disability payments against Cantrell's permanent partial disability benefits, based on a prior ruling. The Court reviewed its precedents and ultimately concluded that a previously relied-upon case (*Lovell II*) was wrongly decided. The Court affirmed the Chancellor's judgment, holding that no set-off of short-term disability benefits against statutory permanent disability benefits is permissible, citing public policy and Tennessee Code Annotated, § 50-6-114.

Workers' CompensationPermanent Partial DisabilityShort-Term Disability BenefitsSet-off DenialEmployer-Funded Disability PlanStatutory InterpretationPublic PolicyTennessee LawOverruling PrecedentTemporary Total Disability
References
8
Case No. 2016-01-0035 / 67325-2014
Regular Panel Decision
Aug 07, 2017

Findley, Jack v. Volswagen Group of America, Inc.

This case involves an employee, Jack Keith Findley, who sustained a back injury while working for Volkswagen. He sought temporary and additional permanent partial disability benefits, leading to a dispute over his impairment rating, maximum medical improvement date, and the compensability of his condition. The Court of Workers' Compensation Claims sided with Mr. Findley, awarding him the requested disability benefits and future medical care under Dr. Jolley, based on Dr. Hodges' medical opinion regarding his work-related injury and functional limitations. The court also allowed Volkswagen to offset short-term disability payments.

Workers' CompensationPermanent Partial DisabilityTemporary Partial DisabilityMedical BenefitsImpairment RatingMaximum Medical ImprovementVoluntary ResignationMedical Opinion ConflictBack InjuryLumbar Disc Herniation
References
5
Case No. MISSING
Regular Panel Decision

Demontbreun v. CNA Insurance Companies

The case involves June Demontbreun's appeal to obtain long-term disability benefits from her former employer's insurance carrier, CNA. Demontbreun injured her back while working for Ingram and Associates, but resigned before her disability officially began in June 1985. CNA denied her claim, arguing she was not eligible as she was not an active employee at the onset of her disability. The Circuit Court for Sumner County initially ruled in Demontbreun's favor based on a jury's finding of total disability. However, the appellate court reversed this decision, stating that the group disability policy only covers active employees who become disabled while insured, and Demontbreun's disability began after her resignation, making her ineligible. The complaint against CNA was dismissed with prejudice.

Long-Term Disability BenefitsGroup Insurance PolicyEmployee EligibilityOnset of DisabilityEmployment TerminationWorkers' CompensationInsurance Coverage DisputesContract InterpretationJury Verdict ReversalERISA Preemption Mentioned
References
10
Case No. 05-CV-1573
Regular Panel Decision

Magin v. Cellco Partnership

This action was brought under ERISA by David Magin against Verizon Wireless entities and MetLife Corporation after his short-term disability benefits were denied. Plaintiff also implicitly sought long-term disability benefits. The court considered cross-motions for summary judgment. Applying an arbitrary and capricious standard of review, the court found MetLife's denial of short-term disability benefits was not an abuse of discretion, citing a lack of material medical evidence. The claim for long-term disability benefits was dismissed as it was never properly filed. Consequently, the defendants' motion for summary judgment was granted, and the plaintiff's complaint was dismissed.

ERISADisability BenefitsShort Term DisabilityLong Term DisabilitySummary JudgmentAbuse of DiscretionDe Novo ReviewFiduciary DutyClaims DenialMedical Evidence
References
38
Case No. MISSING
Regular Panel Decision

Medoy v. Warnaco Employees' Long Term Disability Insurance Plan

Plaintiff, Audrey Medoy, sued Warnaco Employees’ Long Term Disability Insurance Plan and Warnaco, Inc. (Defendants) under ERISA, alleging wrongful termination of disability benefits, failure to provide requested documents, and failure to retain claims records. Medoy's disability benefits were discontinued in 1987 without notice. After years of requesting information and appealing the decision, which was hampered by the destruction of her claims file, she filed this action in 1997. Defendants moved to dismiss the complaint, arguing that the claims were untimely, that Medoy was not a 'participant' entitled to disclosure, and that ERISA § 1027 did not cover claims records. The court denied Defendants' motion to dismiss on all grounds, finding her claims timely, her status as a 'participant' colorable, and claims records subject to retention under ERISA § 1027.

ERISALong-term Disability BenefitsStatute of LimitationsFailure to DiscloseRecord RetentionFutility ExceptionAccrual of ActionPlan Administrator DutiesParticipant StatusMotion to Dismiss
References
37
Case No. 2016-01-0303
Regular Panel Decision
Sep 23, 2016

Buckner, Douglas A. v. Eaton Corporation

Douglas A. Buckner, an employee of Eaton Corporation, sought medical and temporary disability benefits for a spinal injury allegedly sustained at work. The employer, Eaton, contested the claim, arguing insufficient notice and lack of expert medical evidence for work-related causation. The Workers' Compensation Judge, Thomas Wyatt, ruled that Mr. Buckner had a reasonable excuse for delayed notice and that medical opinions, particularly from Dr. Mazza, sufficiently established the work-relatedness of his herniated disc injury. The court ordered Eaton to provide medical benefits and temporary disability payments but allowed for reimbursement of previously paid short-term disability benefits.

Workers' CompensationExpedited HearingMedical BenefitsTemporary DisabilityNotice RequirementSpinal InjuryHerniated DiscCausationEmployer LiabilityMedical Evidence
References
9
Case No. 05-15-01449-CV
Regular Panel Decision
Dec 29, 2016

Donald Videtich v. Transport Workers Union of America, AFL-CIO

Donald Videtich appealed the trial court's grant of summary judgment in favor of Transport Workers Union of America (TWU) on his breach of contract claim. Videtich argued that TWU's Sick Leave & Short-Term Disability Policy altered his at-will employment status, guaranteeing him short-term disability benefits and continued employment for twelve months, and that he was not required to seek administrative remedies. The appellate court identified ambiguities in the Disability Policy regarding its modification of at-will employment and Videtich's eligibility for benefits. It also found unresolved fact issues concerning the formation of a bilateral or unilateral contract and whether Videtich was bound by the International Administrative Committee's (IAC) decision or required to exhaust internal TWU Constitutional appeals. Consequently, the court reversed the summary judgment and remanded the case for further proceedings.

Breach of contractAt-will employmentDisability policySummary judgmentAppellate reviewInternal remediesEmployment terminationLabor lawTexas lawContract ambiguity
References
13
Case No. MISSING
Regular Panel Decision

Rector v. Sylvania

Plaintiff Sylvia Rector sued her former employer, Osram Sylvania, alleging disability discrimination under the Americans with Disabilities Act (ADA) after her termination. Rector suffered a shoulder injury requiring surgery and received short-term and long-term disability benefits. She was eventually cleared to return to work without restrictions, but Sylvania was undergoing a reduction in force and had no available position. The court granted Sylvania's motion for summary judgment, concluding that Rector's temporary shoulder injury did not constitute a disability under the ADA as it lacked the required permanent or long-term impact on a major life activity.

ADADisability DiscriminationSummary JudgmentEmployment LawShoulder InjuryTendonitisImpingement SyndromeTemporary DisabilityMajor Life ActivityReduction in Force
References
15
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