In Stephen J. Kotyk v. Ford Motor Company, Plaintiff Stephen Kotyk and his Michigan Disability Attorney sought reinstatement of his disability benefits after Defendant Ford Motor Company wrongfully terminated his benefits contending he was no longer disabled under Defendant’s Salaried Disability Plan.
Background facts of the case
Based on Plaintiff’s application for disability benefits, he was deemed “disabled” since March 14, 2006 under the Social Security Act. Defendant subsequently denied Plaintiff’s claim for disability benefits relying on the conclusions of its reviewing doctors that Mr. Kotyk was able to perform the duties of his own occupation and was thereby disqualified from receiving benefits. Defendant made its determination despite convincing evidence to the contrary.
Court reviews Magistrate Judge’s conclusion that Defendant’s denial of benefits was not arbitrary and capricious.
Following Defendant’s adverse determination, a Magistrate Judge recommended that Defendant’s Administrative Decision in this ERISA governed action be upheld. Subsequently, Plaintiff filed objections to the Judge’s “Report and Recommendation” and the U.S. District Court for the Eastern District of Michigan reviews the record.
The Magistrate Judge concluded that Defendant’s denial of benefits was not arbitrary and capricious and should be upheld. The District Court disagrees explaining that in conducting its review under the arbitrary and capricious standard, “a court will uphold the administrator’s decision if it is the result of a deliberate, principled reasoning process and if it is supported by substantial evidence.”
Court explains that a plan administrator’s selective review of the administrative record is improper.
After reviewing the entire administrative record, the Court found that Defendant had selectively relied on portions of the record and failed to provide an adequate explanation for its denial of disability benefits. In denying Plaintiff’s benefits, Defendant relied on the opinion of Dr. Norman Pollak who was hired to conduct an independent medical evaluation of Plaintiff.
The Court found the determination puzzling because Dr. Pollock’s conclusions were contrary to the weight of the remaining medical evidence on the record. Additionally, Defendant had Dr. Heckman review Plaintiff’s claims. In conducting his review, Dr. Heckman seemed to completely disregard objective medical evidence in support of Plaintiff’s claims and offered no reasonable explanation to justify the omission.
Medical records support finding that Plaintiff is disabled due to severe lumbar pain.
Upon review of the record, the Court noted that Dr. Heckman made his findings regarding Plaintiff based on a file review and rejected without sufficient reasoning the findings of a doctor who had physically examined Plaintiff. Moreover, contrary to Dr. Heckman’s determination, there was substantial evidence offering support for the conclusion that Plaintiff was disabled during the contested period of time which Dr. Heckman disregarded.
Defendant’s decision denying him disability benefits was inconsistent with Defendant’s decision to grant Plaintiff a disability retirement.
Based on the same disability, Defendant had granted Plaintiff a disability retirement. To justify this, Defendant maintained that the requirements of the retirement plan for establishing “disability” differed from those set forth in the Salaried Disability Plan. Plaintiff argued that Defendant’s granting of a disability retirement and subsequent denial of Plaintiff’s claim for disability benefits was inconsistent. The Court noted that Defendant had failed to offer any sort of reasoned explanation as to how those plans differ.
Due to the record’s great quantity of support evidencing Plaintiff’s disability and Defendant’s failure to consider the evidence while relying heavily on its own doctors’ reports the Court concluded that Defendant’s determination was arbitrary and capricious. Accordingly, the Court ordered the plan administrator to award Plaintiff disability benefits retroactive to the date on which Plaintiff’s benefits ceased.