Eleventh Circuit Affirms Summary Judgment In ERISA Disability Case

In a significant decision affecting the Firm’s group disability insurance clients, the Eleventh Circuit Court of Appeals affirmed a summary judgment in favor of the insurer in a suit for ERISA disability benefits. The claimant argued she was totally disabled by virtue of her chronic migraine headaches but failed to produce any objective documentation of her condition. The Court of Appeals rejected her contention that it was wrong for the administrator to require objective proof of a disability that was primarily subjective in nature and held that the decision to deny benefits was not arbitrary or capricious as a matter of law. The case was handled in the trial court and on appeal by Firm member, David Schmidt. (2006 WL 2220822; 11th Cir., August 4, 2006.)

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Related Member                            

David F. Schmidt