The Fourth Circuit issued an unpublished per curiam opinion today in Scott v. Eaton Corp. Long Term Disability Plan. The panel, composed of Judges Motz, King, and Duncan, unanimously reversed a district court decision (Senior Judge Herlong, D.S.C.) that reversed a disability plan’s denial of benefits. The appellate panel accepted the plan’s argument that its decisionmaking process was sound and that its ultimate decision was supported by substantial evidence. After setting forth the law that an ERISA plan administrator’s decision is reviewed for abuse of discretion, the court wrote:
The record is clear that Eaton thoughtfully considered the views of Dr. Riley. Eaton and its reviewers discussed Dr. Riley’s views, but gave them little weight because of their inconsistency and the fact that many of them were not based on objective evidence. Furthermore, Dr. Riley’s conclusions–those of a well-meaning family doctor–were contradicted by several specialists, who gave no indication of unreliability. It was not unreasonable to discount Dr. Riley’s conclusions in these circumstances.