LOCATION:United States Court of Appeals for the Ninth Circuit
DOCKET NO.: 02-469
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit
CITATION: 538 US 822 (2003)
ARGUED: Apr 28, 2003
DECIDED: May 27, 2003
Lisa Schiavo Blatt – argued the cause for the United States as amicus curiae urging reversal
Lisa S. Blatt – Department of Justice, argued the cause for the United States, as amicus curiae, supporting the petitioner
Lee T. Paterson – Argued the cause for the petitioner
Lawrence D. Rohlfing – Argued the cause for the respondent
Facts of the case
With the recommendation of his doctor, Kenneth Nord filed for disability benefits with his employer of 25 years, Kwikset Corp., a company owned by Black & Decker Corp. After the company denied his claim, Nord asked for a review of the denial. A doctor hired by the company determined that Nord could in fact perform the duties required by his job and was therefore ineligible for benefits, despite determinations to the contrary by Nord’s physician, his orthopedic surgeon and a Black & Decker human resource representative. Nord sued to have the decision reversed, claiming that the company’s preference of its doctor’s opinion over the opinions of the other physicians violated the Employee Retirement Income Security Act of 1974. The district court ruled in favor of Black & Decker Corp. The 9th Circuit Court of Appeals reversed.
Under ERISA, are companies required to defer to the decision of a disability claimant’s personal physician?
Media for Black & Decker Disability Plan v. Nord
Audio Transcription for Opinion Announcement – May 27, 2003 in Black & Decker Disability Plan v. Nord
William H. Rehnquist:
The opinion of the Court in No. 02-469, Black & Decker Disability Plan versus Nord will be announced by Justice Ginsburg.
Ruth Bader Ginsburg:
Under a rule adopted by the Social Security administration, in determining whether a claimant is entitled to Social Security disability benefit, special weight is accorded opinions of the claimant’s treating physician.
The question presented in this case, does a similar rule favoring opinions of treating physicians apply to disability determinations under Employee Benefit Plans covered by the Employee Retirement Income Security Act of 1974 an act known to the Bar and Bench as ERISA?
The answer we hold is no, treating physician opinions need not be favored over other evidence relevant to the claimant’s medical condition.
ERISA and the Secretary of Labor’s regulations under that act require full and fair evaluation of claims and when benefits are denied, clear communication to the claimant of the specific reasons for the denial.
These prescriptions by their terms did not command plan administrators to accord special deference to the opinions of treating physician.
Should a treating physician will be adopted for whatever potential it may have to increase the accuracy of disability determination under ERISA plans?
That question, we think is one the legislature or superintending administrative agency is best position to address.
Critical differences between the Social Security disability program and ERISA benefit plans portion against judicial importation of an agency ordered treating physician rule from the former area into the latter.
Social Security is an obligatory nationwide program in which the decision maker evaluates the claimant’s condition under a uniform set of federal criteria.
ERISA plans come in different sizes and shapes; benefit determinations under those plans are likely to turn in large part on interpretation of the terms of the particular plan at issue.
Absent Department of Labor endorsement, today’s opinion settles courts may not order application of a treating position rule to ERISA governed employee benefit claims.
The District Court so held in this case but the Court of Appeals for the Ninth Circuit disagreed declaring that a treating physician rule does apply to disability plans covered by ERISA.
Finding that declaration erroneous, we vacate the Ninth Circuit judgment and we ran the case for further proceedings.
The decision is unanimous.