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3rd Cir. – Link Between Physical and Mental Conditions Limits Claim

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  • 3rd Cir. – Link Between Physical and Mental Conditions Limits Claim

    Here’s a new case out of the Third Circuit, Kristen Ann Davies v. First Reliance Standard Life Insurance Company. The plaintiff was paid through the own occ and mental/nervous limitation period. The court finds that she is up against a tough burden to prove that she is disabled both from any occupation and that her mental disabilities do not contribute to her disability status. Unfortunately for her, the court concludes that First Reliance’s decision was not arbitrary and capricious.

    The problem for Davies is that the medical evidence she needs to support her claim that she is totally disabled from any occupation also confirms that her depression and anxiety contribute to her disability. Davies concedes that the record is replete with references, several of which the District Court listed and which we need not reiterate here, linking her physical and psychiatric conditions. Davies Br. 27. In fact, the evidence Davies cites is more than sufficient to establish that First Reliance’s termination decision was not arbitrary and capricious. See, e.g., Davies Br. 6 (according to Davies’s treating psychiatrist, hers is a “complicated case and it is very hard to separate how much [of her] symptoms are coming from depression”).

    And as the District Court correctly observed, what little evidence Davies presents that does not link her physical and psychiatric conditions—her mother’s observations and subjective beliefs, criticisms of the independent rheumatologist’s report, and potential side effects of her medications—does not satisfy her burden to show that she is physically incapable of performing any occupation. The independent medical examiners’ opinions that Davies was not totally disabled merely reinforce the conclusion that a “multitude of evidence” already supports. App. 17.

    Our assessment of the structural and procedural factors underlying First Reliance’s decision does not alter this conclusion. “Since Glenn, we have only been willing to disturb an administrator’s decision based on a conflict of interest if evidence either suggests the conflict actually infected the decisionmaking or if the conflict is one last straw that calls a benefits determination into question.” Dowling v. Pension Plan for Salaried Emps. of Union Pac. Corp. & Affiliates, 871 F.3d 239, 251 (3d Cir. 2017). We agree with the District Court that many of Davies’s asserted “procedural shortcomings” are conclusory and unsupported. Others, such as an allegation that a First Reliance claim reviewer’s notes “assuming” Davies “seem[ed]” to have the capacity for sedentary work were improper, App. 299–300, are either inconclusive or unpersuasive in the face of ample support for the termination decision found in the records of Davies’s own treating physicians.
    The opinion is attached below.
    Attached Files