In a recent case, Marcin v. Reliance Standard Life Insurance Company and Mitre Corporation Long Term Disability Insurance Program, No. 16-7125, __F.3d__, 2017 WL 2818648 (D.C. Cir. June 30, 2017), the Court of Appeals for the District of Columbia, ruled against Reliance Standard Life Insurance Company and upheld an award of benefits, costs, and attorneys’ fees under an ERISA governed disability insurance policy for a claimant, Jill Marcin. Ms. Marcin suffers from multiple medical conditions including kidney cancer, portal vein thrombosis, Factor V Leiden (a mutation of one of the clotting factors in the blood called factor V which, increases the chance of developing abnormal blood clots, usually in the veins – including pulmonary embolisms), splenorenal shunt, polycystic ovarian syndrome, and anemia.
In 2008, Ms. Marcin originally filed her claim for long-term disability insurance benefits under her policy with Reliance Standard. Reliance Standard denied Ms. Marcin’s claim and ultimately denied her administrative appeal. Ms. Marcin filed a lawsuit in 2010 and the district court remanded the claim back to Reliance Standard for further review. On remand, Reliance Standard again determined that Ms. Marcin was not disabled and denied her claim for benefits. Ms. Marcin filed her second lawsuit in 2013. This time, the district court entered judgment in favor of Ms. Marcin, finding that the record before the court did not contain sufficient evidence to support Reliance Standard’s adverse benefit decision. However, the district court explained that it “was not making a finding that Ms. Marcin was Totally Disabled.” The district court also found that Ms. Marcin was entitled to monthly disability benefits (which it calculated as a percentage of her full annual salary at the time of the onset of her disability), post-judgment interest on the benefits previously withheld by Reliance Standard, and awarded attorneys’ fees in the amount of $72,240.00.
Reliance Standard appealed the district court’s decision to the Court of Appeals for the District of Columbia. It argued that the district court could not award benefits without first making a factual finding that Ms. Marcin was Total Disability. While the Court of Appeals agreed, under the de novo standard of review for summary judgment decisions, the Court found that Ms. Marcin proved Partial Disability, which is equivalent to Total Disability in Ms. Marcin’s disability policy.
Reliance Standard also argued that the district court incorrectly calculated Ms. Marcin’s monthly disability benefit amount by considering Ms. Marcin’s full salary of $90,000 a year. Reliance Standard argued that Ms. Marcin’s benefit should be lower, as she worked reduced hours prior to officially stopping work and filing her claim for disability benefits. However, the Court of Appeals disagreed and upheld the district court’s calculation of disability benefits owed to Ms. Marcin.