Lamantia

Defendant Hewlett-Packard Company Employee Benefits Organization Income Protection Plan (“the Plan”) appeals the district court’s grant of summary judgment in favor of plaintiff Karen LaMantia awarding her disability benefits. The Plan argues that the district court committed three errors in holding that LaMantia’s complaint was timely, in applying the treating physician rule, and by reviewing the claims administrator’s decision under a de novcj standard of review. We agree with the district court that LaMantia’s complaint was timely. However, because the district court erred in applying the treating physician rule and erred in reviewing the claims administrator’s decision under a de novo standard of review, we reverse and remand for reconsideration of whether LaMantia was improperly denied disability benefits.

FACTS AND PROCEEDINGS BELOW

LaMantia was employed at Hewlett-Packard for fourteen years and was a member of the Plan, which provides disability benefits to qualifying claimants. The Plan’s claims administrator, Voluntary Plan Administrators (“VPA”), makes the determination whether a claimant is “totally disabled” under the Plan’s definitions. The member is entitled to…