Corey v. Sedgwick Claims Management Services, Inc.

Summary

The Sixth Circuit held that medications and a treatment plan qualified as objective findings under an employer disability plan's terms. Because the plan administrator failed to explain why the claimant's documented treatment for cluster headaches did not satisfy that requirement, its denial of short-term disability benefits was arbitrary and capricious. The court vacated the district court's judgment and remanded with instructions to remand the matter to the administrator for further review.

Holdings

1. Corey's documented medications and treatment plan satisfied the plan's definition of objective findings because the plan expressly listed medications and/or treatment plan as examples of objective findings.
2. The administrator's denial was arbitrary and capricious because it issued a conclusory denial, failed to explain why Corey's medications and treatment plan did not qualify as objective findings, and offered no other reasoned analysis.

Questions Presented

1. Whether the plan administrator acted arbitrarily and capriciously by denying short-term disability benefits for lack of objective findings without considering or explaining why Corey's documented medications and treatment plan did not satisfy the plan's definition of objective findings.
2. Whether the administrator could defend its denial with a post-hoc interpretation requiring medication or treatment to cause the disability or objectively confirm inability to work.

Disposition

vacated