United States First Circuit
Gross v. Sun Life Assurance Company of Canada, 12-1175
The district court's decision upholding defendant-insurer's denial of disability benefits to plaintiff is vacated and remanded, where: 1) the employer's insurance benefits program is an Employee Retirement Income Security Act (ERISA) plan; 2) the district court correctly concluded that the safe harbor exception to ERISA is inapplicable; but 3) the benefits denial was subject to de novo review because the language requiring proof of disability "satisfactory to us" is inadequate to confer the discretionary authority that would trigger deferential review; and 4) the administrative record is inadequate to allow a full and fair assessment of plaintiff's entitlement to disability benefits.
Appellate Information
- Decided 08/16/2013
- Published 08/16/2013
Judges
- LIPEZ
Court
- United States First Circuit