Facts

Plaintiff Martha Winkler was a nurse employed by the American National Red Cross. She suffered a cardiac arrest and filed a claim for long term disability benefits under the Red Cross' Long Term Disability Plan, which was self-funded by the employer. Aetna was named as the authority to review her claim and the parties agreed that the standard of review was abuse of discretion. Aetna initially approved Winkler's benefits, but then terminated them after the medical records did not evidence a functioning impairment that prevented her from performing her work. Winkler appealed, but the denial was upheld. Winkler filed to suit to compel payment of benefits.

Winkler moved the court to consider evidence outside the Administrative Record. The motion was denied.

PLAINTIFF'S CONTENTIONS:
Winkler claimed Aetna wrongly denied her claim, in violation of ERISA.

DEFENDANT'S CONTENTIONS:
The defense contended that Aetna did not abuse its discretion in denying the claim. The defense asserted that no procedural irregularity existed which could lead the court to weigh a conflict of interest more heavily. The defense contended that Aetna reviewed the medical records and simply came to a decision that was contrary to what Winkler's treating physician's concluded. The defense contended that Winkler's medical records lacked specific notes and follow-up and other information in the records contradicted the conclusion of the physicians.

Result

The court issued a defense verdict, finding that Aetna did not abuse its discretion in denying Winkler's claim.