Holder v. Woodmen of the World, 248 F.3d 1134 (4th Cir. 2000) – decided April 13, 2001 - United States Court of Appeals for the Fourth Circuit – Robert E. Hoskins

As an attorney, I have gotten more “mileage” out of this unpublished case over the years than any other with the possible exception of Cothran v. Reliance Standard, 1999 U.S. App. LEXIS 31588 (4th Cir. 1999).  (Click here to see the discussion of Cothran from this cite.)  I wish Holder was published, but even though it is not it has proved very useful in the years since its issuance.  Holder was a relatively routine ERISA disability case.  The plan in which Ms. Holder participated was self-funded by her employer, Woodmen of the World, and the case was decided under an abuse of discretion standard.  (Click here to view an excellent discussion about the abuse of discretion standard from my Evans case as discussed in this site.)  On Holder, I lost in the district court and appealed to the United States Court of Appeals for the Fourth Circuit who ruled with my client.  It was nice for the Fourth Circuit panel to reverse the district court and rule with my client.  What has proved particularly useful over the years is the reason the Fourth Circuit reversed.  The administrative record in Holder contained a letter from Ms. Holder’s primary treating physician dated March 1999.  In that letter, the doctor inferred that Ms. Holder might be able to work at a sedentary job.  A few months later, the same physician completed an affidavit wherein he opined definitively that Holder was, in fact, disabled from doing any job, even a sedentary one.  The district court had found that the doctor’s statements were contradictory and that, under the circumstances, it was not unreasonable for the plan to rely upon the earlier statement in denying Ms. Holder’s claim.  (Click here to view the district court opinion)  However, the Fourth Circuit disagreed and held:

“With these standards in mind, we find that the district court erred by granting summary judgment for the Plan.  Although Drakeford’s March 1999 letter suggests that Holder could work at a sedentary job, his subsequent letters contradict this conclusion.  In May 1999, he stated that Holder had reached her maximum recovery.  A month later, he opined that she likely would not be able to work full-time because of her physical impairments.  In December 1999, he stated that Holder was totally disabled from working full-time or on a consistent basis and had been since her car accident.  Drakeford’s opinion that Holder was totally disabled was also supported by Dr. Stewart.

In light of the fact that the more recent evidence supports a finding that Holder suffered from a total disability and that the only evidence to the contrary was an initial letter from Holder’s treating physician who later concluded that Holder had reached maximum recovery and was totally disabled, we find that summary judgment in favor of the Plan was not appropriate.  We therefore vacate the district court’s order and remand for further proceedings consistent with this opinion.” 

(Click here to view the Fourth Circuit’s opinion)