Seventh Circuit Court of Appeals Denies Request for Discovery Outside of Claim File

In February of 2018, the Seventh Circuit Court of Appeals issued an instructive decision in the case of Dragus v. Reliance Standard Life Insurance Company. This dispute centered around an employee who brought a claim for long term disability benefits under a plan covered by the Employee Retirement Income Security Act (ERISA). Unfortunately, his claim was denied by the insurance company. Here, our Chicago ERISA litigation attorney discusses this case and highlights the important lesson that all ERISA disability claimants can take from it.

Case Analysis: Dragus v. Reliance Standard Life Insurance Company

Background

Mr. Dragus was employed as a sales manager at a company based in Chicago, Illinois. In 2011, he underwent a major spinal surgery to deal with severe neck pain. Sadly, there were complications associated with the operation. Eventually, he applied for, and received short-term disability benefits.

Soon after, he submitted a claim against Reliance Standard Life Insurance Company for long term disability benefits. In 2014, the insurance company (Reliance Standard) denied his long term disability claim on the grounds that the presented medical evidence did not support a condition at the level of severity that would have made the claimant unable to perform material duties of the job.

Decision

After the long term disability claim denial was upheld by a lower court, Mr. Dragus filed an appeal with the Seventh Circuit. Among other issues, Mr. Dragus’s appeal noted that he had received a favorable Social Security disability (SSDI) decision in 2015. However, the lower court refused to allow Mr. Dragus to supplement the record with this decision. The Seventh Circuit Court of Appeals affirmed that decision, noting that courts do not allow parties to present new evidence in ERISA cases when the dispute is about whether or not an insurance company denial is ‘arbitrary and capricious’.

The Lesson

ERISA disability lawsuits have special evidentiary rules. With very limited exceptions, courts will not allow disability claimants to provide supplemental evidence. Courts are largely restricted to reviewing evidence that is already in the claim file. This is why it is so important for ERISA beneficiaries to get an attorney involved in their case as soon as possible. Your lawyer will ensure that all relevant evidence gets into the official claim file.

Contact Our Chicago ERISA Attorneys Today

At Bartolic Law, our Chicago ERISA litigation lawyer has helped many people recover full and fair disability compensation. To request a free, no obligation review of your case, please call us today at (312) 635-1600. With an office in Chicago, our law firm serves communities throughout Northern Illinois, including in Cook County, DuPage County, and Lake County.