Eighth Circuit Defines How Summary Judgment Procedures Apply to ERISA Benefit Claim Reviews
Vanilla ERISA claims seeking plan benefits may well be the most common lawsuit encountered by federal judges. Even so, the Federal Rules of Civil Procedure do not expressly contemplate how these ERISA claims for benefits—with their unique limits on discovery and discretionary standard of review (in most cases). Courts have therefore had to find ways to fit ERISA claims for benefits within existing procedural rules, and have come up with varying approaches for how to do so.
Courts, for example, have had to determine how claims for benefits need to be finally resolved. Since no jury trial is appropriate and since the evidence is generally limited to that in the administrative record, courts generally recognize that no trial is necessary. Further, given that most cases are resolved under an abuse of discretion standard, the normal rules for summary judgment—only allowing for summary judgment where there is “no genuine issue of material fact”—don’t really fit, given that there a claim for benefits should generally be resolved in the fiduciary’s favor if there is disputed evidence in the record.
In Avenoso v. Reliance Standard Life Ins. Co., the Eighth Circuit had to determine how an ERISA claim for benefits should be resolved under the Federal Rules of Civil Procedure. The case was a straightforward one: Plaintiff sought disability benefits under a disability plan administered by Standard Life Insurance. But unlike many ERISA cases, this case would be decided under a de novo standards of review that gave no weight to the fiduciary’s factual conclusions and plan interpretations. The Eighth Circuit concluded that it was improper for the Court to have resolved this matter on a summary judgment motion—because the case was decided under a de novo standard, the court could only resolve the case by making factual determinations, which would be improper on a summary judgment standard. But the Eighth Circuit suggested that resolving a case on a summary judgment motion would have made sense if the case had been decided under the discretionary abuse of discretion standard as the mere presence of facts in the record supporting the fiduciary would usually mandate that summary judgment be granted.
In the end, however, the Court ruled that any error was harmless. Although the Court should have resolved the case at trial (perhaps on the papers under Rule 52), the parties acknowledged that there was no further evidence that they wanted to present. Further, the Court made it clear what factual findings it would have made, and thus made it clear how it would have ruled had the proper procedure been followed. Because any error was harmless, the Eighth Circuit ultimately affirmed, while providing valuable guidance to parties going forward.