Daniel Kunin v. Benefit Trust Life Insurance Company

Benefit Trust Life Insurance Company (“Benefit Trust”) appeals the decision of the district court awarding benefits to Daniel Kunin (“Kunin”). Kunin, the Senior Vice-President of Maxim’s Beauty Salons, Inc., incurred over $50,000 in medical bills for the treatment of his child for autism. Kunin sought reimbursement of his expenses under a group health insurance policy issued to his employer; the parties agree that this policy is itself an “employee welfare benefit plan” governed by ERISA, and that Benefit Trust functioned as both insurer and plan administrator. Following a brief investigation, Benefit Trust agreed to pay $10,000, but no more, on the ground that autism fell within the policy’s limitation for “mental illness.” The district court concluded that autism is not a mental illness and that the denial of benefits was arbitrary and capricious, and ordered that the claim be paid in full. We agree that Benefit Trust was obligated to pay the full amount of the claim.

Benefit Trust’s medical director’s cursory investigation did not provide reasonable grounds for determining that autism is a mental illness. The testimony of Kunin’s experts amply supports the finding that Benefit…