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Savage v. Quicken Loans and Affiliated Companies Welfare Benefits Plan

United States District Court, E.D. Michigan, Southern Division

August 20, 2019

MARY SAVAGE, Plaintiff,
v.
QUICKEN LOANS AND AFFILIATED COMPANIES WELFARE BENEFITS PLAN, Defendant.

          Stephanie Dawkins Davis Mag. Judge

          ORDER DENYING PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT [ECF No.30] AND GRANTING DEFENDANT'S MOTION FOR JUDGMENT ON THE ADMINISTRATIVE RECORD [ECF No. 31]

          Victoria A. Roberts United States District Judge

         I. INTRODUCTION

         Mary Savage brings this action against Quicken Loans and Affiliated Companies Welfare Benefits Plan (the “Plan”) alleging that it wrongfully denied her claim for short-term disability benefits in violation of the Employee Retirement Income Security Act (“ERISA”).

         The Plan moves for judgment on the administrative record; it says that its denial of Savage's claim was not arbitrary and capricious and that it properly relied on the opinion of its reviewing physician, meaning that this Court must uphold its denial of benefits.

         The Court agrees with the Plan. Its motion is GRANTED; Savage's motion is DENIED.

         II. BACKGROUND

         This case arises out of the Plan's denial of Savage's claim for short-term disability benefits. At all times relevant, Savage was employed by Quicken Loans as a collateral loan underwriter.

         On August 24, 2016, Savage submitted a claim for short-term disability benefits. Her claim was submitted under the Plan. Under the relevant terms of the Plan, a participant must provide proof that he or she is disabled to qualify for benefits; a participant is disabled if he or she is “unable to perform the Material and Substantial duties of [his or her] own job.”

         The Plan also gives the Plan Administrator the authority to “interpret the provisions of the Plan and determine any question arising under the Plan, or in connection with the administration or operation thereof, including questions of fact.” Notably, the Plan Administrator has “discretionary authority to interpret the provisions of the Plan and the facts and circumstances of claims for benefits, and to decide questions of fact related thereto.” The Plan Administrator may also delegate its duties to “a third-party claims administrator or such other persons as the Plan Administrator deems appropriate.”

         The Plan delegated claim administration responsibilities to Liberty Life Assurance Company of Boston (the “Administrator”); the Plan provided that a participant must provide satisfactory proof to Liberty to be eligible for short-term disability benefits.

         Savage says she suffered debilitating stress and anxiety because of an alleged workplace incident. Liberty denied both her initial claim and her appeal, stating that she failed to provide “objective medical evidence demonstrating that [she] was unable to perform the material functions of her job.” Savage says that Liberty's denial was arbitrary and capricious in violation of ERISA. She requests that the Court reverse the denial and grant her short-term disability benefits.

         III. STANDARD OF REVIEW

         Section 502(a)(1)(B) of ERISA authorizes an individual to bring an action “to recover benefits due to him under the terms of his plan, to enforce his rights under the terms of the plan, or to clarify his rights to future benefits under the terms of the plan.” 29 U.S.C. § 1132(a)(1)(B). In Wilkins v. Baptist Healthcare Sys., Inc., the Sixth Circuit ...


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