Lynd v. Reliance Standard Life Ins. Co., 94 F.3d 979 (5th Cir. 1996) - Pursuant to the employer's ERISA plan, long-term disability benefits automatically terminate after two years if the employee's disability is due to "mental or nervous disorders" unless the disability results in hospitalization. Employee, who was diagnosed with a major depressive disorder, brought action to appeal the termination of his LTD benefits. The Fifth Circuit affirmed the district court's grant of summary judgment to the defendant. It held that regardless of the standard of review (de novo or abuse of discretion, the employer properly determined that employee's depression was a mental rather than physical disorder. Although the employee presented a medical opinion that major depression has a physiologic basis, the administrator did not err in giving a lay person's definition to the terms of the plan, and properly concluded that a depressive disorder is mental in nature. The terms should be accorded their ordinary and not specialized meanings.
