Todd Roehr v. Sun Life Assurance Company of Canada

Summary

In this ERISA long-term disability benefits case, the Eighth Circuit reversed the district court's judgment for Sun Life, holding that the plan administrator abused its discretion by terminating benefits without new significant evidence. The court ruled that Sun Life's reliance on essentially the same medical records it had accepted for a decade—including intermittent tremor findings and a single ambiguous notation—did not constitute substantial evidence to support termination, and that the administrator's failure to follow its own neurologists' recommendations for further evaluation was an abuse of discretion. The decision reinforces that a plan administrator cannot change its mind on the same evidence without a significant change in circumstances, and that a conflict of interest (dual role as administrator and insurer) is weighed as a factor but does not automatically warrant a less deferential standard.

Holdings

1. Sun Life's termination of Roehr's LTD benefits was an abuse of discretion because it was not supported by substantial evidence; the record lacked any significant change in Roehr's condition from the evidence Sun Life had accepted for nearly a decade.

Questions Presented

1. Whether the district court erred in granting Sun Life's motion for judgment on the record by applying the correct standard of review.
2. Whether Sun Life abused its discretion in terminating Roehr's long-term disability benefits without substantial evidence of a change in condition.

Disposition

reversed_and_remanded