Morgan
v. Sun Life Of Canada, 2000
U.S. App. LEXIS 21243 (6th Cir. Aug 16, 2000) (unpublished)
In 1993 Morgan, working as a secretary, suffered congestive heart failure and had to have an aortic valve surgically replaced. She subsequently applied for disability benefits. Sun Life deemed Morgan totally disabled and granted her disability benefits. However, Sun Life required her to furnish further satisfactory evidence of her continuing disability when necessary.
In 1995 Sun Life said that to remain totally disabled Morgan must provide continuing proof of her disability and prove she could not engage in any occupation, not just her former occupation as a secretary. She submitted three Attending Physician Statements ("APS") from George R. Chaney, M.D., which stated that Morgan had congestive heart failure and would never be able to perform any work. However, she did not submit any medical records or doctor notes to support Dr. Chaney's conclusion that she was totally disabled.
Sun Life requested and received all of Dr. Chaney's notes and medical records. Based on the objective medical evidence, Sun Life concluded that Morgan had a satisfactory outcome from her valve replacement surgery. Moreover, the medical evidence did not support Dr. Chaney's claim that she was totally disabled. She could work and was not eligible for total disability benefits.
Morgan appealed Sun Life's decision but failed to submit any further medical evidence. Sun Life affirmed its decision. Morgan sued in state court. Defendants removed the case. The district court ruled that Sun Life was not arbitrary and capricious in denying Morgan disability benefits.
The
issue was whether Sun Life acted arbitrarily and capriciously in denying Morgan
disability benefits. Under an
arbitrary and capricious standard of review, the district court cannot determine
that a plan administrator erred if his decision is "'rational in light of
the plan's provisions.'" Yeager v. Reliance Standard Life Ins., Co., 88 F.3d 376, 381 (6th Cir. 1996), quoting Miller
v. Metropolitan Life Ins. Co., 925
F.2d 979, 984 (6th Cir. 1991).
The plan required Morgan to provide evidence of disability to the satisfaction of Sun Life. Reviewing the APS, Dr. Chaney's medical notes, and Sun Life's initial medical review of Morgan's files, it was clear to the Sixth Circuit that Sun Life's decision to discontinue Morgan's disability benefits was rational. The APS that Dr. Chaney completed stated that Morgan had congestive heart failure and as a result, was totally disabled. However, Dr. Chaney's notes revealed that Morgan was not suffering from any symptoms of heart failure. Further, when Sun Life explained its reasoning why it believed Morgan was no longer totally disabled, Morgan failed to submit any additional evidence.
Morgan also claimed that Sun Life failed to properly notify her of its decision to terminate her benefits because Sun Life stated in its letter to her "that in at least 4 separate examinations over the past year you have had no symptoms of heart failure...." Morgan claimed that Sun Life erred by not specifically indicating the four examinations to which it was referring.
Although Sun Life did not specifically provide the dates of the exams Morgan only visited Dr. Chaney eight times in the previous year. Three of those visits related to problems with sinusitis and tonsillitis and Morgan never saw Dr. Chaney. Thus, during the only visits in the relevant year where Dr. Chaney actually saw Morgan, he conducted a routine follow-up exam on Morgan for the aortic valve replacement surgery she had in 1993. Therefore, this lack of dates should not have confused Morgan.