Angels v. Reliance Standard Life Insurance
Docket: No. 05-2298-CV
Court: Court of Appeals for the Second Circuit; February 2, 2006; Federal Appellate Court
The judgment of the district court is affirmed, dismissing Geoffrey Angels's ERISA claim regarding the denial of his long-term disability benefits by Reliance Standard Life Insurance Company. Angels argues that the district court improperly applied a deferential standard in reviewing the benefits denial, asserts he meets the definition of "Total Disability" under the policy, and claims Reliance is liable for a default judgment against the Graham-Field, Inc. Long Term Disability Plan. The court reviews the benefit plan as a whole, emphasizing plain meanings of terms. It concludes that the definition of "Total Disability" is unambiguous and that Angels does not qualify as totally disabled according to this definition. The Plan distinguishes between "Total Disability" and "Partial Disability," with the former requiring the inability to perform any material duty of one’s regular occupation. Since Angels could perform some material duties during the Elimination Period, his claim was justifiably denied. Regarding Reliance's liability for the Plan's default judgment, the court finds no provision in the Plan that holds Reliance responsible for judgments against third parties. As the insurer is not liable for claims not covered by the policy, Reliance is not accountable for the default judgment. The court thoroughly considers Angels's remaining arguments and finds them without merit, leading to the affirmation of the district court’s decision.