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Burk v. Broadspire Services, Inc.

Citation: 342 F. App'x 732Docket: No. 07-3729

Court: Court of Appeals for the Third Circuit; August 18, 2009; Federal Appellate Court

Narrative Opinion Summary

In this ERISA case, the plaintiff sought reinstatement of her long-term disability (LTD) benefits from Highmark Life Insurance Company and Broadspire Services, Inc., after her benefits were terminated. The plaintiff initially received LTD benefits due to significant back issues but was later determined by Broadspire to be capable of performing sedentary work based on medical evaluations and surveillance footage. The district court applied a deferential arbitrary and capricious standard of review, due to Broadspire’s discretionary authority under the policy, and granted summary judgment in favor of the defendants. The court found that substantial evidence supported the termination of benefits, including assessments indicating the plaintiff could engage in some forms of employment. It noted that ERISA does not require special weight to be given to treating physicians' opinions and that the Social Security Administration's disability determination was not binding under the plan. On appeal, the court upheld the denial, confirming no abuse of discretion in Broadspire's decision-making process, despite the plaintiff's claims of procedural irregularities and the consideration of surveillance footage. The case underscores the challenges beneficiaries face when contesting LTD benefit terminations under ERISA standards.

Legal Issues Addressed

Consideration of Treating Physicians' Opinions

Application: The court noted that ERISA does not require special weight for treating physicians' opinions, and found that Broadspire acknowledged these evaluations but determined Burk could perform sedentary work.

Reasoning: Although Burk alleged procedural irregularities, including the dismissal of her treating physicians' opinions... the court noted that ERISA does not require special weight for treating physicians' opinions and found Burk's claims unsupported by the record.

ERISA Standard of Review

Application: The court applied a deferential arbitrary and capricious standard due to Broadspire's discretionary authority under the LTD policy.

Reasoning: The District Court, upon cross-motions for summary judgment, determined that Broadspire’s decision was subject to a deferential arbitrary and capricious standard due to Broadspire's discretionary authority granted by Highmark’s LTD policy.

Non-Binding Nature of Social Security Disability Determinations

Application: The court found that the Social Security Administration’s disability determination was not binding under the terms of the ERISA plan.

Reasoning: The Social Security Administration’s disability determination was deemed non-binding in the context of the plan terms.

Role of Surveillance in Claims Decisions

Application: Surveillance footage was considered as part of the evidence supporting the decision to terminate Burk's benefits, showing her engaging in active behavior.

Reasoning: The court clarified that Broadspire’s use of various assessments, including the January 2004 FCM Assessment and subsequent evaluations, was valid and... supported by evidence such as surveillance footage showing Burk engaging in active behavior.

Termination of Long Term Disability Benefits

Application: The termination of Burk's LTD benefits was upheld by the court, finding that Broadspire's decision was supported by substantial evidence, including medical assessments and surveillance footage.

Reasoning: The District Court upheld Broadspire's denial of benefits, finding sufficient evidence even under a heightened arbitrary and capricious standard of review, which is more favorable to Burk than the Glenn standard.