Ryson Carter v. Westinghouse Savannah River Company, LLC, 207 U.S. Dist. LEXIS 63919 (D.S.C. 2007) – decided August 29, 2007 – United States District Court for the District of South Carolina – Robert E. Hoskins

In this case, the plaintiff sought long term disability benefits from an ERISA governed plan established, administered and funded by his employer. The plan had denied the plaintiff’s claim and the plaintiff had fully exhausted his administrative remedies before filing suit in the U.S. District Court for the District of South Carolina. The case was decided under a pure abuse of discretion standard. Even under that most deferential of standards, the District Court reversed the plan’s decision and ruled that the plaintiff was entitled to the benefits he sought. The court reasoned:

“This Court is fully cognizant of the deferential substantial evidence standard of review applicable to the Court when it reviews an ERISA denial of benefits claim. Consistent with this deferential standard and considering the record as a whole, the Court must nevertheless ensure that the record contains some evidence beyond a mere scintilla that would allow reasonable minds to concur in the conclusion reached by Defendant. Mindful of this deferential standard, the record yields, at best, a mere scintilla of evidence to support Defendants’ decision that Plaintiff’s claim should be denied. Defendants’ finding that Plaintiff was not entitled to TPD benefits was not reasonable inasmuch as it was not the result of a deliberate, principled reasoning process and it was not supported by substantial evidence. Bernstein, 70 F.3d at 788. There is, however, substantial evidence in the record for this Court to conclude that Plaintiff is disabled according to the terms of the plan. Accordingly, the Court must reverse the decision of Defendants.”

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