Long Term Disability Law Blog
In Marcin v. Reliance Standard Life Insurance Company, et al., Reliance appealed a ruling of the U.S. District Court for the District of Columbia in which the District Court found that Jill Marcin was entitled to long-term disability benefits in the amount of $2,409.74 a month plus interest and attorney’s fees. The U.S. Court of Appeals for the District of Columbia Circuit ruled in favor of Marcin and upheld the ruling of the lower court.
The case has a long procedural history beginning in 2008 when Jill Marcin, a multi-discipline systems engineer for a non-profit organization, first applied for long-term disability benefits based on her diagnosis of, among other things, kidney cancer. Her claim was denied and thus began her long fight through “two lawsuits, at least three remands, and now an appeal.”
The Appellate Court noted that, “While the procedural posture of this case is tortuous, the issue we must decide is relatively straightforward: did Ms. Marcin prove Total Disability in accordance with the terms of the plan? The factual evidence in this case shows that she did.”
Ms. Marcin Proved She Is Totally Disabled
The Court of Appeals reviewed the policy definition of total disability and Marcin’s “voluminous medical records, her work history, witness statements, and scientific literature concerning her illness.” The Court also reviewed the reports of reviewing physicians hired by Reliance. The Court made several conclusions:
- Marcin’s medical records show that “Marcin could not sustain a full-time work schedule. Reliance’s conclusions to the contrary based on this evidence are therefore unreasonable.”
- Marcin’s work history “supports a finding of Partial Disability.”
Reliance argued that the District Court failed to make a factual finding that Marcin was totally disabled, a prerequisite for awarding benefits. The Court of Appeals agreed that was a prerequisite and that the lower court had not made that specific finding. However, the Appellate Court determined that since it was conducting a de novo review, it could affirm on any ground and “elect to do so on the basis that Ms. Marcin proved Partial Disability. According to the express terms of the Plan, Partial Disability is equivalent to Total Disability, and we find that Ms. Marcin was Totally Disabled within the relevant period.”
The District Court Correctly Calculated the Disability Benefit Amount
The Court of Appeals did not go into detail about why the District Court correctly calculated the benefit amount. It simply concluded that, “because we find Ms. Marcin’s salary at the time of disability was $90,000, we affirm the District Court’s calculation of benefits owed.”
This case was not handled by our firm, but if you are facing a similar protracted process in your claim for disability benefits, or have any question at all about any aspect of your disability claim, feel free to contact one of our disability attorneys at Dell & Schaefer for a free consultation.