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Weird LTD Opinion – S.D. Ga.

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  • Weird LTD Opinion – S.D. Ga.

    Weird LTD Opinion – S.D. Ga.

    Attached is a case out of the Southern District of Georgia, Lord v. American General Life Insurance Company of Deleware. I can honestly say that I have never read an opinion quite like this. In fact, when I read the opinion I did a little investigating on both the internet and Pacer because I could not understand it.

    The case involves a claim for LTD benefits. The plaintiff worked for the Georgia Ports Authority, however, the case was decided as an ERISA case. It caught my attention because my firm has handled cases for the South Carolina Ports Authority, and we handled them as non-ERISA cases. I did a little digging, and the Georgia Ports Authority is clearly a governmental entity. I then went to Pacer to check out the procedural history on the case. It looks like the case was originally plead on non-ERISA grounds. Defendant removed, asserting that the claim was governed by ERISA, and it does not look like plaintiff ever challenged the removal or that the claim was governed by ERISA. In fact, in an opinion footnote, the court stated:

    In her Complaint, Plaintiff does not expressly bring any claims under ERISA and instead sets forth state-law claims for breach of insurance contract and bad faith refusal to pay. (See Doc. 1-1.) However, through 29 U.S.C. § 1444(a), Congress mandated that ERISA “shall supersede any and all State laws insofar as they may now or hereafter relate to any employee benefit plan.” In the context of challenging an insurance claim decision, Congress intended ERISA’s civil remedies, provided by 29 U.S.C. § 1132(a), “to be the exclusive vehicle for actions by ERISA-plan participants and beneficiaries asserting improper processing of a claim for benefits.” Alexandra H. v. Oxford Health Ins. Inc., 833 F.3d 1299, 1317 (11th Cir. 2016) (quoting Pilot Life Ins. Co. v. Dedeaux, 481 U.S. 41, 52 (1987)). Thus, ERISA preempts Plaintiff’s state-law causes of action as they concern improper claim processing. Moreover, despite not explicitly alleging an ERISA claim in her Complaint, Plaintiff does not contest that it controls her challenge to Defendant’s denial of long-term disability benefits. (See Doc. 22.)
    Defendant argues that it did not abuse its discretion under ERISA, and plaintiff responds to defendant’s motion, also using ERISA as the controlling law which, frankly, I believe is incorrect. In any event, the court grants defendant’s motion for summary judgment, finding that it did not abuse its discretion in denying plaintiff’s long term disability benefits.
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