“Beckstrand V. Electronic Arts Group Long-Term Disability Insurance Plan”
“Beckstrand v. Electronic Arts Group Long-Term Disability Insurance Plan”
2008 U. S. Dist. LEXIS 831950 (E. D. Cal. September 16, 2008)
Mr. Beckstrand formerly worked for Electronic Arts. He became disabled in 1998, submitted a claim for LTD benefits under Electronic Arts’ insured plan, and was paid benefits into 2004, although his benefits were terminated and reinstated on and off throughout that time period. After his benefits were terminated in 2004 Mr. Beckstrand appealed and the appeal was denied. He then hired us to represent him in a lawsuit.
In its first ruling on our lawsuit, the district court ruled against Mr. Beckstrand and entered judgment in favor of the plan. However, there was a new decision by the appellate court and we requested that the district court vacate the judgment and reconsider its decision in light of that new decision, which the Court did – and then allowed us to conduct discovery to obtain new evidence. We conducted discovery to explore the plan’s conflict of interest, then resubmitted the case to the trial judge for a decision based on the old record and the newly discovered evidence. On retrial, the district court took into account the new evidence we submitted and ruled in favor of Mr. Beckstrand. The district court reasoned that the plan and its doctors disregarded an earlier medical opinion by one of the plan’s doctors that supported Mr. Beckstrand’s disability status and relied upon the plan’s doctors’ most recent opinions without even addressing the countervailing opinions of Mr. Beckstrand’s own doctors and the previous opinion of one of the plan’s doctors. Second, the district court reasoned that the plan failed to notify Mr. Beckstrand that it had changed its position that Mr. Beckstrand’s medications caused his symptoms or notify Mr. Beckstrand that he needed to provide evidence of other diagnoses and treatment which he had not previously provided. Third, the district court explained that the plan was unfair to Mr. Beckstrand because no one told him that his failure to be treated for one of his conditions was a reason for the denial of his benefits until the final appeal denial letter. Fourth, the district court concluded that the plan’s analysis of the evidence was simply mistaken with regard to Mr. Beckstrand’s medications. Fifth, the plan failed to consider Mr. Beckstrand’s award of Social Security Disability benefits and failed to address the Social Security Administration’s finding that Mr. Beckstrand was totally disabled while concluding that Mr. Beckstrand was not disabled under the plan’s similar standard. Sixth, the Court noted that paper reviews of a claimant’s medical records and the failure to conduct a physical examination where the plan reserves the right to do so, while not as such improper, raise concerns about the thoroughness and accuracy of the benefits determination, especially when the paper reviews contain conclusions that involve critical credibility determinations regarding a claimant’s medical history and symptomatology. Therefore, the Court, after the second trial, ordered reinstatement of Mr. Beckstrand’s benefits retroactively.