Davis v. Aetna Life Insurance Company (Aetna) involves a case where a plaintiff filed an ERISA lawsuit against Aetna alleging that she should receive long-term disability benefits under her employee benefit plan. As it turns out, there was no evidence she had ever submitted a claim for benefits. When Aetna filed its Motion for Summary Judgment, plaintiff failed to file an opposition. The Court determined there was no material issue of triable fact and granted Aetna’s motion.
Deborah Davis, employee of Capital One, witnessed her husband’s death when he was pinned under a vehicle. She sought medical help due to her emotional distress, extreme grief and insomnia. She requested leave under the Family Medical Leave Act (FMLA), which was denied. Capital One ultimately fired her.
In her ERISA suit, plaintiff asserted that she never received a final determination of her claim for disability nor did she ever receive disability benefits. She alleged Aetna “breached its fiduciary duty by arbitrarily and capriciously failing to pay her benefits.” She requested the federal district court to order Aetna to pay her past and future long-term disability benefits. The Louisiana District Court refused her request on several grounds and granted Aetna’s Motion for Summary Judgment.
The plaintiff bore the burden of proving her case, and she failed. Davis would only be entitled to disability benefits if the plan administrator certified that she was so entitled. Here, the plan administrator, on multiple occasions, requested that Davis provide medical documentation supporting her claim that she could not perform her job responsibilities.
According to the record, she never even filed a claim and never provided any medical evidence to document her disability. She also failed to exhaust any administrative remedy.
Plaintiff also failed to respond to Aetna’s Motion for Summary Judgment. The Court noted that she provided no evidence to support her claim against Aetna, “or to rebut Defendants’ arguments.” The Court ultimately concluded that, “As Plaintiff has not demonstrated a genuine issue of any material fact, the Court finds Defendant is entitled to summary judgment.”
This case was not handled by our office, but we hope it demonstrates the need to file a claim for disability benefits, and to follow up that claim with supporting evidence. Claimant’s must respond to requests from plan administrators for medical documentation. If you have any questions about this case, or any questions about your claim for disability benefits, contact one of our attorneys at Dell & Schaefer for a free consultation.