Heather Cogdell v. Reliance Standard Life Insurance Company
Split Score
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Case Summary
Disposition
Affirmed
The Fourth Circuit held that when an ERISA disability-plan administrator fails to issue a decision on an internal appeal within the 45-day regulatory deadline (and cannot justify an extension with valid “special circumstances”), the administrator forfeits any discretionary authority and the district court must review the benefit denial de novo. Because Reliance Standard issued its appeal decision 25 days late and without a valid extension, the panel affirmed the district court’s de-novo ruling that Heather Cogdell is entitled to long-term-disability benefits.
Circuit Split Identified
Legal Issue
Whether an ERISA plan administrator’s untimely decision on an internal appeal eliminates deferential (abuse-of-discretion) judicial review and requires a court to apply de-novo review of the benefit claim.
Circuit Positions
Untimely or absent appeal decision forfeits discretionary authority; courts apply de-novo review.
Procedural/timing violation is only a factor within abuse-of-discretion review; discretion is not forfeited.
Conflict Summary
Several circuits treat a missed regulatory deadline as a forfeiture of fiduciary discretion, mandating de-novo review of the claim, while other circuits view the timing violation as merely a procedural irregularity that is weighed under abuse-of-discretion review but does not change the standard.