Karen McClain v. Eaton Corp. Disability Plan

How courts have described this case

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

• holding that when reviewing a denial of benefits under ERISA, a court may consider only the evidence available to the administrator at the time the final decision was made
• holding that, when a benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan, then a denial of benefits is reviewed only to determine if it was arbitrary and capricious
• rejecting plaintiff’s argument that ability to do part-time sedentary work was “pittance” that was insufficient to find her able to do other work under plan definition of disability
• finding it reasonable for an administrator to decide a claimant did not meet a policy’s definition of “disabled to engage in any occupation” when the claimant could work part-time
• finding it reasonable for an administrator to decide a claimant did not meet a policy’s definition of “disabled to engage in any occupation” when the claimant could work part-time
• “An ‘extremely deferential review,’ to be true to its purpose, must actually honor an extreme level of deference to the administrative decision.”

Source: CourtListener parenthetical corpus (CC0).