United States First Circuit

In claim against defendant-insurer and plan administrator for long term disability (LTD) benefits under an employee group benefit plan governed by ERISA, judgment awarding LTD benefits to plaintiff for maximum time period available under the plan is affirmed, where: 1) in an addiction context, a risk of relapse can be so significant as to constitute a current disability; 2) under the language of the plan, categorically excluding risk of relapse as a source of disability is simply unreasonable; and 3) the district court did not abuse its discretion in awarding retroactive benefits and plaintiff attorneys' fees.

Appellate Information

• Decided 01/17/2013
• Published 01/17/2013

Judges

• SELYA

Court

• United States First Circuit

Counsel