Sobhani v. Reliance Standard Life Ins. Co.
The Second Circuit, on December 18, 2015, affirmed the District Court of Connecticut’s summary judgment ruling in favor of Reliance Standard Life Insurance Company (“Reliance”) in Jeffrey Sobhani’s action for disability benefits under the Employee Retirement Income Security Act of 1974. In a brief Summary Order, the court quickly explained disability benefit determinations are reviewed under a de novo standard of review. Except “when, as in this case, written plan documents confer upon a plan administrator the discretionary authority to determine eligibility, de novo review does not apply; rather, we will not disturb the administrator’s ultimate conclusion unless it is arbitrary and capricious.” Sobhani v. Reliance Standard Life Ins. Co., No. 14-3430-CV, 2015 WL 9245104, at *1 (2d Cir. Dec. 18, 2015) (internal quotation marks omitted).
Mr. Sobhani made two arguments before the circuit court, (1) the record before the district court was not the official administrative record and (2) Reliance’s denial of benefits was arbitrary and capricious. The circuit court declined to address Mr. Sobhani’s first argument as he failed to raise it before the district court, therefore waiving the argument. In review of Mr. Sobhani’s second argument, the court reviewed the definitions of “Total Disability,” “Partial Disability,” “Regular Occupation,” and “Elimination Period” in the relevant disability policy. In reviewing these definitions, the court found Reliance did not act arbitrarily and capriciously when it determined Mr. Sobhani’s claim failed because “his medical records [did] not support a Total or Partial Disability” and “he did not meet the Total or Partial Disability requirements throughout the entire 180-day Elimination Period.” Id. at *2 (internal quotation marks omitted). The record showed Mr. Sobhani continued to work full-time for approximately eight weeks following his claimed date of disability. The circuit court, in agreeing with the district court, concluded it was reasonable for Reliance to determine Mr. Sobhani did not meet the elimination period and therefore its determination was not arbitrary and capricious.
No. 14-3430-CV, (2d Cir. Dec. 18, 2015)