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Wirries v. Reliance Standard Life Insurance

Citation: 247 F. App'x 870Docket: No. 05-35941

Court: Court of Appeals for the Ninth Circuit; August 10, 2007; Federal Appellate Court

Narrative Opinion Summary

The case involves an appeal by Reliance Standard Life Insurance Company challenging the district court's decision to reverse its termination of long-term disability benefits for an insured individual. The central legal issue pertains to the alleged abuse of discretion by the district court in changing its opinion regarding the denial of benefits, as well as the interpretation of the term 'regular occupation' within the insurance policy. Initially, the district court had erred in conducting a de novo review, but upon remand, it corrected its approach by relying on substantial evidence from the record. The appellate court supports the district court's interpretation that the term 'regular occupation' accurately referred to the insured's previous job duties, which were more demanding than the standard description provided by the Department of Labor's Dictionary of Occupational Titles. Additionally, the appellate court affirmed that Reliance's reliance on a medical study introduced late in the process, which failed to consider the insured's specific medical conditions, constituted an abuse of discretion. Ultimately, the appellate court affirmed the district court's judgment, maintaining the insured's entitlement to disability benefits, while noting that the ruling is not precedential under 9th Cir. R. 36-3 unless specified otherwise.

Legal Issues Addressed

Abuse of Discretion in Benefits Denial

Application: The court determined that Reliance abused its discretion by relying on a medical study not applicable to the insured's condition and introduced only during the appeal.

Reasoning: Reliance's reliance on the medical study, which was introduced only during the appeal process, denied Ms. Wirries the chance to contest its validity.

Interpretation of Insurance Policy Terms

Application: The appellate court agreed with the district court's interpretation of 'regular occupation' as the insured's job before the onset of the disability, rejecting Reliance's misinterpretation claim.

Reasoning: The district court concluded that 'regular occupation' explicitly refers to the insured's job before the onset of disability.

Law of the Case Doctrine

Application: The appellate court reviewed the district court's change in opinion on the reasonableness of the denial of benefits and found no abuse of discretion.

Reasoning: Reliance argues that the district court’s change in opinion regarding the reasonableness of the denial of benefits contradicts the law of the case doctrine, which is reviewed for abuse of discretion.