Cheriese Johnson v. Reliance Standard Life Insurance Company
Split Score
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Case Summary
Disposition
Reversed
The Eleventh Circuit held that Reliance Standard Life Insurance Company wrongfully denied Cheriese Johnson long-term disability benefits under an ERISA-governed plan by misreading the policy’s pre-existing-condition exclusion. The court found that Johnson had not received treatment "for" scleroderma during the policy’s look-back period and therefore the exclusion did not apply, reversed the district court’s grant of summary judgment for Reliance, and remanded for further proceedings.
Circuit Split Identified
Legal Issue
Proper judicial standard for reviewing an ERISA plan-administrator’s benefits denial when the plan grants discretionary authority.
Circuit Positions
Apply Eleventh Circuit’s six-step ERISA review framework (de-novo wrong inquiry followed by arbitrary-and-capricious review).
Apply classic arbitrary-and-capricious/abuse-of-discretion review whenever discretionary language exists, without the Eleventh Circuit’s preliminary de-novo inquiry.
Conflict Summary
The Eleventh Circuit continues to apply its unique six-step sequencing framework that first asks whether the administrator was 'de-novo wrong' and then, if discretion exists, moves to an arbitrary-and-capricious inquiry, whereas at least six sister circuits skip the 'de-novo wrong' step and apply a straightforward arbitrary-and-capricious (abuse-of-discretion) standard whenever the plan vests the administrator with discretion.