Dona McLeod v. Reliance Standard Life Insurance Company, and John Does 1-10

Summary

The United States District Court for the District of Montana adopted a magistrate judge’s findings and recommendation in an ERISA dispute concerning the reduction of Dona McLeod’s long-term disability benefits. The court held that the governing policy unambiguously permitted Reliance Standard Life Insurance Company to offset McLeod’s benefits by the amount of her lump-sum employer pension distribution, including funds rolled into an IRA. The court granted Reliance Standard’s motion for summary judgment, denied McLeod’s motion, and dismissed the action with prejudice.

Holdings

1. Because the policy did not grant Reliance Standard discretionary authority, the court reviewed the benefits determination de novo rather than for abuse of discretion.
2. The policy unambiguously permitted Reliance Standard to offset McLeod's long-term disability benefits by the amount of her lump-sum pension distribution, including the amount rolled into an IRA.
3. Contra proferentem did not apply because the policy was not genuinely ambiguous after ordinary principles of contract interpretation were applied.
4. Reliance Standard was entitled to summary judgment, and McLeod was not entitled to summary judgment.

Questions Presented

1. Whether the district court should adopt the magistrate judge's recommendation granting Reliance Standard summary judgment and denying McLeod summary judgment.
2. Whether the ERISA plan's lack of discretionary-authority language required de novo review of Reliance Standard's benefits determination.
3. Whether the policy unambiguously permitted Reliance Standard to offset McLeod's long-term disability benefits by the amount of her employer-funded lump-sum pension distribution rolled into an IRA.
4. Whether contra proferentem required construing any ambiguity in the policy in McLeod's favor.

Disposition

dismissed