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United States Court of Appeals for the Ninth Circuit
July 28, 2022, Argued and Submitted, Pasadena, California; November 21, 2022, Filed
PAEZ, Circuit Judge:
Vicki Collier ("Collier") appeals the district court's judgment in favor of Lincoln Life Assurance Company of Boston ("Lincoln") in an action arising under the Employee Retirement Income Security Act of 1974 ("ERISA"), 29 U.S.C. § 1001 et seq. Collier filed a claim for long-term disability ("LTD") benefits through her employer-sponsored disability insurance policy ("the Plan"), which was administered by Lincoln. Lincoln denied Collier's claim for LTD benefits. Collier then pursued an internal appeal, but Lincoln again denied her claim. On de novo review, the district court affirmed Lincoln's denial of Collier's claim. In so doing, the district court adopted new rationales that the plan administrator did not rely on during the administrative process.
] We reverse and remand. When a district court reviews de novo a plan administrator's denial of benefits, it examines the administrative record without deference to the administrator's conclusions to determine whether the administrator erred in denying benefits. See Abatie v. Alta Health & Life Ins. Co., 458 F.3d 955, 963 (9th Cir. 2006) (en banc); Kearney v. Standard Ins. Co., 175 F.3d 1084, 1088-89 (9th Cir. 1999) (en banc). The district court's task is to determine whether the plan administrator's decision is supported by the record, [*4] not to engage in a new determination of whether the claimant is disabled. Accordingly, the district court must examine only the rationales the plan administrator relied on in denying benefits and cannot adopt new rationales that the claimant had no opportunity to respond to during the administrative process.
The district court erred because it relied on new rationales to affirm the denial of benefits—rationales that Lincoln did not assert during the administrative process. See Harlick v. Blue Shield of California, 686 F.3d 699, 719-20 (9th Cir. 2012). Specifically, the district court found for the first time that Collier was not credible, and that she had failed to supply objective medical evidence to support her claim. As Lincoln did not present these rationales during the administrative process, Collier was afforded no opportunity to respond to them, and was denied her statutory right to "full and fair review" of the denial of her claim. See 29 U.S.C. § 1133(2). Accordingly, we reverse and remand for the district court to reconsider Collier's claim de novo, with no deference to the administrator's decision, and to determine whether the record evidence supports the reasons on which Lincoln relied to deny benefits.
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2022 U.S. App. LEXIS 32042 *; __ F.4th __; 2022 WL 17087828
VICKI COLLIER, Plaintiff-Appellant, v. LINCOLN LIFE ASSURANCE COMPANY OF BOSTON, Defendant-Appellee.
Prior History: [*1] Appeal from the United States District Court for the Central District of California. D.C. No. 8:20-cv-00839-JVS-KES. James V. Selna, District Judge, Presiding.
Disposition: REVERSED AND REMANDED.
district court, benefits, plan administrator, claimant, credibility, disability, administrative process, pain, first time, de novo review, reasons, occupation, accommodations, administrative record, claim for benefits, medical evidence, denial letter, restrictions, ergonomic, symptoms, records
Administrative Law, Judicial Review, Standards of Review, De Novo Standard of Review, Pensions & Benefits Law, Handling of Claims, Scope of Review, Civil Procedure, Appeals, Clearly Erroneous Review, De Novo Review, Questions of Fact & Law, Civil Litigation, Causes of Action, Suits to Recover Plan Benefits, Governments, Legislation, Interpretation