Grant v. Waterfront Employers, 4th Cir. (1998)
Grant v. Waterfront Employers, 4th Cir. (1998)
See Sheppard & Enoch Pratt Hosp., Inc. v. Travelers Ins. Co., 32
F.3d 120, 123-24 (4th Cir. 1994). If the administrator's decision is
supported by substantial evidence, that decision is not an abuse of discretion. See Boyd v. Trustees of United Mine Workers Health &
Retirement Funds, 873 F.2d 57, 59-60 (4th Cir. 1989).
Grant submits that the Plan did not grant the Trustees discretionary
authority until it was amended in 1995 and therefore the district court
erred in reviewing the Trustees' decision under an abuse of discretion
standard. Because we find that even under the unamended version of
the Plan the Trustees were vested with discretionary authority, we do
not address the issue of the amendment's effect.* In Firestone, the
Supreme Court held that a denial of benefits under ERISA is to be
reviewed under a de novo standard "unless the benefit plan gives the
administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan." Firestone, 489
U.S. at 115. Under the unamended Plan in this case, the trustees were
to serve as named fiduciaries having powers and duties, which
included "interpret[ing] the Plan and . . . determin[ing] the questions
arising in the administration, interpretation and application of the
Plan," "determin[ing] the benefits to be paid to or for the Members
from time to time," and "determin[ing] whether a participant has qualified for benefits under th[e] Plan." We find that the Plan sufficiently
vested the trustees with discretionary authority in determining benefits even before its amendment, and therefore the Trustees' decision
was properly reviewed under an abuse of discretion standard.
We now address whether the Trustees abused their discretion in
denying Grant disability benefits. The Trustees were presented with
the medical opinion of five different physicians, at least three of
whom specialized in orthopaedic medicine. Out of the five, three of
the physicians, two orthopaedic physicians and one family practitioner, after examining Grant, found that he was not totally disabled.
We have reviewed the medical reports and opinions submitted to the
Trustees and find that the Trustees' decision was reasonable and supported by substantial evidence.
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*Although unnecessary for the disposition of this appeal, we note that
the record is unclear as to the year of the Plan's amendment.
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Grant also claims that the district court erred in not considering a
Social Security Administration report concerning Grant's disability.
Because the district court is limited to the evidence that was before
the Trustees at the time of their decision, the court properly declined
to consider this evidence. See Sheppard, 32 F.3d at 125.
In light of the above, we affirm the district court's order upholding
the Trustees' denial of disability benefits to Grant.
AFFIRMED
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