United States Eighth Circuit

In an ERISA action challenging the denial of plaintiff's short-term disability benefits, summary judgment for defendant is affirmed where: 1) the language of the plan defined who was an Approved Health Care Provider, and a physician assistant was not an Approved Health Care Provider; 2) defendant reasonably denied plaintiff's claim for insufficient evidence of a medically certified health condition; and 3) defendant's interpretation of the plan requiring objective medical evidence did not constitute a procedural irregularity and did not trigger a less deferential standard of review.

Appellate Information

• Decided 05/12/2010
• Published 05/12/2010

Judges

Court

• United States Eighth Circuit

Counsel