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Griffin v. Hartford Life & Accident Insurance Co.

United States Court of Appeals, Fourth Circuit

July 31, 2018

SCOTT GRIFFIN, Plaintiff - Appellant,
v.
HARTFORD LIFE & ACCIDENT INSURANCE COMPANY, Defendant-Appellee.

          Argued: May 9, 2018

          Appeal from the United States District Court for the Western District of Virginia, at Lynchburg. Norman K. Moon, Senior District Judge. (6:16-cv-00024-NKM-RSB)

         ARGUED:

          Michael D. Grabhorn, GRABHORN LAW OFFICE, PLLC, Louisville, Kentucky, for Appellant.

          John Cowles Neiman, Jr., MAYNARD COOPER & GALE, P.C., Birmingham, Alabama, for Appellee.

         ON BRIEF:

          Andrew M. Grabhorn, GRABHORN LAW OFFICE, PLLC, Louisville, Kentucky, for Appellant.

          William B. Wahlheim, Jr., Grace R. Murphy, Braxton S. Thrash, MAYNARD COOPER & GALE, P.C., Birmingham, Alabama, for Appellee.

          Before WILKINSON and NIEMEYER, Circuit Judges, and Richard M. GERGEL, United States District Judge for the District of South Carolina, sitting by designation.

          NIEMEYER, CIRCUIT JUDGE

         Scott Griffin commenced this action under the Employee Retirement Income Security Act ("ERISA") against Hartford Life and Accident Insurance Company ("Hartford Life") as the administrator of his employee welfare benefit plan, seeking a continuation of the long-term disability benefits that Hartford Life had terminated based on its conclusion that Griffin was no longer "disabled," as that term is used in the plan.

         The district court granted summary judgment to Hartford Life, and Griffin filed this appeal, contending that the district court erred (1) in reviewing the administrator's decision for abuse of discretion, rather than de novo, and (2) in concluding that Griffin failed to provide evidence sufficient to support a conclusion that Hartford Life's decision to terminate the long-term disability benefits was unreasonable. For the reasons that follow, we affirm.

         I

         Scott Griffin became employed by MedQuist Transcriptions, Ltd., as a medical transcriptionist in April 2010. As an employee, he enjoyed the benefits of MedQuist's employee welfare benefit plan, which included life insurance, short-term disability benefits, and long-term disability benefits. MedQuist provided these benefits through group policies that it purchased from Hartford Life, which was also the administrator of the plan.

         As relevant to this appeal, Griffin's long-term disability benefits were governed by a long-term disability policy that defined disability as follows:

         Disability or Disabled means You are prevented from performing one or more of the Essential Duties of:

(1) Your Occupation during the [180-day] Elimination Period;
(2) Your Occupation, for the 24 month(s) following the Elimination Period, and as a result Your Current Monthly Earnings are less than 80% of Your ...

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