Brown v. Seitz Foods, Inc. Disability Benefit Plan

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• finding that “words like ‘to be considered disabled,’ ‘normally,’ ‘as long as the definition of total disability is satisfied,’ and ‘due . . . proof of loss’ . . . ‘do not trigger the deferential ERISA standard of review.’”
• suggesting a district court should ordinarily limit its review to the evidence contained in the administrative record
• finding de novo standard of review appropriate but holding that district court abused its discretion by admitting evidence outside of administrative record, absent a showing of good cause
• denying benefit coverage when Brown worked up until the day he was fired and therefore could not show that he was unable to perform the duties of his occupation before he was fired
• “to receive benefits, Brown had to show he had become continuously unable to perform the duties of his occupation .... ”
• no good cause where plaintiff could have timely provided additional evidence to plan administrator

Source: CourtListener parenthetical corpus (CC0).