ERISA Rulings by the DC Circuit
The DC Circuit requires that grants of discretion be clear and will not
construe a requirement of "proof of eligibility" to confer discretion.
Additionally, the DC Circuit has found that when a plan term is ambiguous,
it is construed against the plan. In an important DC Circuit case, the
term "mental illness" was not defined and was therefore held
to be ambiguous. The court construed the term against the plan and in
favor of the claimant, concluding that bipolar disorder was not a mental
illness as defined by the plan documents. Obviously, bipolar disorder
is a mental illness, but it has a physical cause. The court's ruling
underscores the importance of clear and explicit definitions of policy
terms and the need for claimants to evaluate their policies carefully
when its terms are not explicitly defined.
The DC Circuit also permits a grant of discretion to be found in documents
other than the actual policy, reasoning that all plan documents must be
examined together to determine the appropriate standard review. This makes
it easier to prove a grant of discretion.
Choose an Experienced ERISA Lawyer
ERISA Law Center serves the DC Circuit by representing claimants in Washington,
D.C. If you are ready to discuss your claim with an experienced ERISA
lawyer, please do not hesitate to call our offices at (844) 710-2993.
We are available 24 hours a day, 7 days a week and offer a free consultation
to help you get started.