Sara Maurer v. Reliance Standard Life Insuran

MEMORANDUM

Plaintiff Sara G. Maurer, the beneficiary of a long-term disability plan (“the Plan”) that is governed by the Employee Retirement and Income Security Act of 1974 (“ERISA”), challenges the discretionary decision of Defendant Rebanee Standard Life Insurance, the Plan’s administrator, to terminate her disability benefits. The district court held that Defendant did not abuse its discretion in terminating her benefits. Because we hold that Defendant permissibly appbed the Plan’s “mental/nervous” limitation to terminate Plaintiffs benefits, we affirm.

1. We assume, without deciding, that we must apply a high level of skepticism in assessing whether Defendant abused its discretion. See Abatie v. Alta Health & Life Ins. Co., 458 F.3d 955, 965-69 (9th Cir.2006) (en banc) (discussing the scope of our review in this context). Even applying a high level of skepticism, the record supports Defendant’s decision to terminate benefits.

2. Defendant permissibly interpreted the “mental/nervous” limitation to preclude coverage when, in the absence of a mental or nervous disorder, a beneficiary would be physically capable of working. Defendant’s interpretation is consistent with the…