Courson v. Bert Bell NFL Player Retirement Plan, 214 F.3d 136 (3^rd Cir. 2000)-Courson, a former NFL football player, appealed the district court's summary judgment in favor of the Retirement Board.  The Retirement Board denied his request to increase his disability benefits.  The plan provided greater benefits to players who suffered football-related disabilities, or disabilities which arose during or shortly after their career.

Courson initially argued that his heart condition, cardiomyopathy[1], was a result of his use of anabolic steroids and alcohol use.  Courson asserted both of which were "league football activities."  The steroids were performance-related and the alcohol was a pain killer. Courson later abandoned his claim that his steroid abuse caused his cardiomyopathy, due to lack of medical evidence of such a connection.  He added a claim that he was due disability benefits based simply upon his alcoholism.

            This court affirmed the district court's summary judgment in favor of the Retirement Board.  The plan vested the Board with complete discretion to determine eligibility for benefits and to construe the terms of the plans.  An arbitrary and capricious standard of review was appropriate.  This court found that the Retirement Board did not abuse its discretion in denying Courson's claims.

Alcohol use or abuse was not a "league football activity" since it was not "required," "directed," or "supervised" by the NFL.  In fact, the NFL took measures to prevent players' alcohol abuse.  Courson's cardiomyopathy therefore did not result from a league activity.  As for Courson's argument that his alcoholism itself was a "disability" which arose during his football career, the Retirement Board found scant evidence that the alcoholism prevented Courson from or make him unable to engage in any occupation or employment for remuneration or profit.