Toni Feibusch v. Integrated Device Technology, Inc. Employee Benefit Plan, and Sun Life Assurance Co. Of Canada

Toni Feibusch (“Feibusch”) appeals the district court’s decision that Sun Life Assurance Co. of Canada (“Sun Life”) did not abuse its discretion in terminating her disability benefits. Feibusch’s principal argument is that the district court incorrectly applied abuse of discretion review rather than de novo review. Feibusch was denied benefits under policy language that states that proof of a disability claim “must be satisfactory to Sun Life.”

We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we hold that de novo review applies under the policy language at issue. We reverse the summary judgment in favor of Sun Life and remand for trial proceedings.

I

FACTUAL BACKGROUND

Beginning in 1984, Feibusch was employed by Integrated Device Technology, Inc. (“IDT”) as a technical writer and administrative assistant. Her job duties included typing, answering phones, and creating and maintaining technical data sheets. In a typical day, she was required to sit for seven to seven and a half hours, stand for one-half to one hour, walk for one-half to one hour, and drive for one-quarter hour. Although her job was largely sedentary, she was occasionally required to bend, stoop, climb,…