Galm v. Eaton Corporation - Northern District of Iowa

Given these five physicians and one psychologist were in unanimity in their
conclusion that Galm was not disabled under the “any occupation” requirement of the Plan,
it is the opinion of this court that, based upon the record before the plan administrator,
Eaton did not abuse its discretion in determining that Galm was not disabled under the
terms of the Plan for second-tier long term disability benefits. This court is satisfied that
based upon the record before the plan administrator that the plan administrator's decision
was supported by substantial evidence and was thus reasonable. See Jackson, 303 F.3d at
887 (stating that a “decision is reasonable if a reasonable person could have reached a
similar decision, given the evidence before him, not that a reasonable person would have
reached that decision”). Therefore, the court concludes that Eaton is entitled to judgment
in its favor on Galm’s claim under ERISA.
III. CONCLUSION
The court concludes that, as a matter of law, on the record here, Eaton’s decision
to deny Galm second-tier long term disability benefits is supported by substantial evidence.
Therefore, the court finds that Eaton is entitled to judgment in its favor on Galm’s claim
under ERISA. The denial of second- tier long term disability benefits was not an abuse of
discretion as a matter of law, because Eaton’s interpretation of the Plan was not
unreasonable and there was substantial evidence supporting Eaton’s determination that Galm
was not “disabled” within the meaning of the Plan.
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