Lang
Lang v. Long-Term Disability Plan of Sponsor Applied Remote Technology, Inc.
Opinion
Lead Opinion
Schroeder, J.
Judith Lang, a former contracts manager for Applied Remote Technology, Inc., appeals the district court’s grant of summary judgment in favor of defendants-appellees on her claim for long-term disability benefits. The appellees are Applied Remote Technology, the sponsor of the welfare benefit plan (the “Plan”) under which Lang claimed the benefits, and Standard Insurance Company, the issuer and administrator of the Plan. In her suit, under Section 502(a)(1)(B) of the Employment Retirement Income Security Act (“ERISA”), 29 U.S.C. § 1132 (a)(1)(B), Lang claims that Standard wrongfully terminated her benefits. Standard contends that its decision to limit Lang’s benefits to two years was proper because her disability was “caused or contributed to” by a “mental disorder,” for which the Plan provided a two-year limit. Lang disagrees that her disability was due to a “mental disorder.” She argues that the Plan is ambiguous as to what constitutes a “mental disorder” and that Standard’s determination was tainted by self-interest. We conclude that Standard’s conflict of interest, arising out of its dual role as the administrator and funding source for the Plan, affected its decision in Lang’s…