Stephanie Dorris v. Unum Life Insurance Company of America

Summary

In an ERISA disability benefits case under de novo review, the Seventh Circuit clarified that the plaintiff bears the burden of proving entitlement to benefits, not merely that the plan administrator erred. The court affirmed summary judgment for the insurer where the plaintiff failed to present evidence on the "any occupation" or "20% less" prongs of the disability definition, as gaps in the record cut against the claimant. The court also held that arguments not adequately raised in the district court—including a cursory assertion of the 20% less option—are waived, and that a district court does not abuse its discretion by limiting review to the administrative record where the plaintiff sought only duplicative discovery and failed to object to a magistrate judge's protective order.

Holdings

1. The district court's finding that Dorris did not provide sufficient evidence to carry her burden under the 'any occupation' option was not clearly erroneous. The court plausibly found that the medical evidence and Social Security decision did not preclude all gainful occupations.
2. The district court did not abuse its discretion because it did not exclude any relevant extra-record evidence that Dorris offered; Dorris never sought additional discovery after the protective order and failed to object to the magistrate judge's order.
3. The district court did not abuse its discretion because the motion sought to correct Dorris's own procedural failure to present evidence, not any error by the court.

Questions Presented

1. Whether the district court clearly erred in finding that Dorris failed to meet her burden of proof under the 'any occupation' prong of the disability definition.
2. Whether the district court abused its discretion in limiting its review to the administrative record.
3. Whether the district court abused its discretion in denying Dorris's motion to amend the judgment.

Disposition

affirmed