Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Fowler v. AT&T Umbrella Benefit Plan No. 3

United States District Court, S.D. Indiana, Indianapolis Division

November 22, 2017

SHANNON FOWLER, Plaintiff,
v.
AT&T UMBRELLA BENEFIT PLAN NO. 3

          ORDER ON PENDING MOTIONS

          MARK J. DINSMORE UNITED STATES MAGISTRATE JUDGE.

         This matter comes before the Court on Plaintiff's Motion for Stay. [Dkt. 28.] For the reasons set forth below, the Court DENIES Plaintiffs motion.

         I. Background

         Plaintiff applied for short term disability ("STD") benefits that are provided to Defendant's employees. Defendant approved and paid Plaintiff STD benefits from January 26, 2016 through September 12, 2016. [Dkt. 1 at 2.] Defendant denied Plaintiff's claim for additional STD benefits after September 12, 2016. rDkt. 28; Dkt. 30.1 Plaintiff appealed Defendant's decision and on January 25, 2017 Defendant denied Plaintiff's appeal. [Dkt. 1 at 2.]

         On March 29, 2017, Plaintiff brought this action alleging Defendant violated the Employee Retirement Income Security Act of 1974 ("ERISA") by prematurely terminating her claim for STD benefits. [Dkt. 1.] At around the same time or shortly thereafter, [1] Plaintiff submitted to Defendant a claim for long term disability ("LTD") benefits related to the same disability and medical conditions she alleges support her claim for STD benefits. [Dkt. 28.] Defendant denied Plaintiff's LTD benefits claim and the claim is pending in Defendant's appeal process. [Id.] Plaintiff now seeks to stay this matter for 120 days to await the outcome of the LTD benefits appeal. [Id.]

         Plaintiff argues that a stay would avoid piecemeal litigation of the STD benefits and LTD benefits claims because assuming Defendant denies her LTD benefits claim, Plaintiff can include that denial within this lawsuit and the Court will be able to adjudicate both claims at the same time. [Dkt. 28.] In response, Defendant argues that if Defendant denies Plaintiff's LTD benefits claim, Plaintiff would not be able to simultaneously litigate her STD benefits and LTD benefits claims because the relevant plan terms require participants to first exhaust fifty-two (52) weeks of STD benefits before being considered for LTD benefits. [Dkt. 30 at 3.] Defendant maintains that it is undisputed Plaintiff did not meet this requirement. [Id.] Moreover, Defendant notes that because Plaintiff did not receive fifty-two (52) weeks of STD benefits, the claims administrator has not even considered whether there was sufficient evidence to satisfy other required criteria. [Id.] Thus, Defendant argues that even if Plaintiff prevails on her STD benefits claim and exhausts the fifty-two (52) weeks of STD benefits, the Court would still be required to remand consideration of the LTD claim back to the claims administrator. [Id. at 4.]

         In reply, Plaintiff argues that Defendant's LTD denial letter dated May 25, 2017 only stated that it denied Plaintiff LTD benefits because she did not first exhaust the required fifty-two (52) weeks of STD benefits. [Dkt. 31 at 2-3.] Thus, under ERISA, Defendant is not allowed to generate new reasons for the denial of her LTD benefits claim besides the sole reason stating in the May 25, 2017 correspondence. [Id.] Consequently, Plaintiff argues that if the Court finds that Defendant prematurely terminated her STD benefits claim, Defendant's basis for denying her LTD benefits claim will become moot and Plaintiff will be entitled to the LTD benefits. [Id. at 5.]

         II. Legal Standard

         "[T]he power to stay proceeding is incidental to the power inherent in every court to control the disposition of the causes on its docket with economy of time and effort for itself, for counsel, and for litigants." Texas Indep. Producers & Royalty Owners Ass'n v. E.P.A., 410 F.3d 964, 980 (7th Cir. 2005) (quoting Landis v. N. Am. Co., 299 U.S. 248, 254 (1936)). "How this can best be done calls for the exercise of judgment, which must weigh competing interests and maintain an even balance." Landis, 299 U.S. at 254-55. "The proponent of a stay bears the burden of establishing its need." Clinton v. Jones, 520 U.S. 681, 708 (1997).

         III. Discussion

         Plaintiff argues that if she prevails on her STD benefits claim and exhausts the fifty-two (52) weeks of STD benefits, she would be automatically eligible to receive LTD benefits. Plaintiff asserts that under ERISA, the initial denial notification must set out every reason for a decision denying benefits. Given the fact that Defendant's LTD denial letter dated May 25, 2017 only stated that it denied Plaintiff LTD benefits because she did not first exhaust the required fifty-two (52) weeks of STD benefits, Plaintiff argues that Defendant is prohibited from generating new reasons for its denial of Plaintiff s LTD benefits claim. Defendant argues that even if Plaintiff exhausts the fifty-two (52) weeks of STD benefits, the Court would still be required to remand consideration of the LTD claim back to the claims administrator to determine whether Plaintiff meets other required criteria. The Court addresses the parties' arguments in turn.

         "ERISA sets certain minimum requirements for procedures and notifications when a plan administrator denies a claim for benefits." Zuckerman v. United of Omaha Life Ins. Co., No. 09- CV-4819, 2011 WL 2173629, at *3 (N.D. 111. May 31, 2011). In a nutshell, ERISA requires the plan administrator to provide specific reasons for the denial of the claim and to give the claimant an opportunity for a "full and fair review." Halpin v. W. W. Grainger, Inc., 962 F.2d 685, 688 (7th Cir. 1992). Section 1133 of ERISA provides:

         In accordance with regulations of the Secretary, every employee benefit plan shall-

(1) Provide adequate notice in writing to any participant or beneficiary whose claim for benefits under the plan has been denied, setting forth the specific reasons for such denial, written in a manner ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.