Galm v. Eaton Corporation - Northern District of Iowa

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B. Application Of The Substantial Evidence Test ................. 25 III. CONCLUSION ........................................ 30 I. INTRODUCTION AND BACKGROUND A. Procedural Background On August 2, 2004, plaintiff Janet M. Galm filed a petition in Iowa District Court In And For Clay County against Eaton Corporation (“Eaton”) under the civil enforcement provision of the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. § 1132(a)(1)(B), seeking long-term disability benefits under an employee welfare benefit plan (“the Plan”) sponsored by her former employer, Eaton. On August 26, 2004, defendant Eaton removed this case to this court pursuant to 28 U.S.C. § 1441(a), alleging jurisdiction based on ERISA’s express federal jurisdictional provision found in 28 U.S.C. § 1332(e). In Galm’s petition, she alleges that Eaton denied her second-tier long-term disability benefits under the Plan, in violation of ERISA. In its answer, Eaton admits denying Galm second-tier long-term disability benefits, but alleges the denial of these benefits was reasonable and not arbitrary or capricious. Following the court’s granting plaintiff Galm’s request to conduct discovery, see Galm v. Eaton Corp., 360 F. Supp. 2d 2
978, 984-986 (S.D. Iowa 2005), both parties have filed briefs on the merits centered on the central issue in this case, whether plaintiff Galm is disabled under the terms of the Plan. The court turns first to a discussion of the undisputed facts as shown by the record and the parties’ submissions, then to consideration of the standards applicable to judicial review of benefits determinations under ERISA, and, finally, to the legal analysis of whether Eaton’s decision to deny Galm second-tier long-term disability benefits was supported by substantial evidence. B. Factual Background The record reveals that the following facts are undisputed. Plaintiff Janet M. Galm worked as an induction hardener/machinist for Eaton for almost thirteen years. As an Eaton employee, Galm participated in an employee welfare plan to provide long-term disability benefits to participants who became disabled and unable to work. The Plan, which is administered by Eaton, has a two-tier disability benefit structure. Under the first tier of the Plan, a participant has a covered disability if, during the first twenty-four months of her disability, the participant is unable to perform the duties of her occupation with Eaton. Under the second-tier, the definition of disability changes and the Plan provides that: Record at 000014. during the continuation of such total disability following the first 24 months, you are totally and continuously unable to engage in any occupation or perform any work for compensation or profit from which you are, or may become, reasonably well fitted by reason of education, training or experience —at Eaton Corporation or elsewhere. 3
Page 1: To Be Published: IN THE UNITED STAT
Page 5 and 6: in his decision: Record at 00026. T
Page 7 and 8: certified in physical medicine and
Page 9 and 10: year did not indicate any ongoing p
Page 11 and 12: the absence of significant sensory
Page 13 and 14: Record at 001359. intention to rece
Page 15 and 16: Record at 000197. Galm is not emplo
Page 17 and 18: 1. Deferential review Under the def
Page 19 and 20: c. The deferential review applicabl
Page 21 and 22: plan administrator, “something ak
Page 23 and 24: U.S. 1136 (2000)). This is particul
Page 25 and 26: determinations under the Plan. Reco
Page 27 and 28: Record at 001628. With all of the a
Page 29 and 30: Record at 001359. to the effects of
Page 31: IT IS SO ORDERED. DATED this 3rd da

Galm v. Eaton Corporation - Northern District of Iowa

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