Black & Decker Disability Plan v. Nord
538 U.S. 822 (2003)
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Rule of Law:
The Employee Retirement Income Security Act of 1974 (ERISA) does not require employee benefit plan administrators to accord special weight or deference to the opinion of a claimant's treating physician when making disability benefit determinations.
Facts:
- Kenneth L. Nord was an employee of a Black & Decker subsidiary, working as a material planner in a job classified as 'sedentary.'
- In 1997, Nord experienced hip and back pain and consulted Dr. Leo Hartman, who diagnosed him with mild degenerative disc disease.
- Dr. Hartman advised Nord to cease work temporarily and referred him to a treating orthopedist.
- Nord submitted a claim for disability benefits under the Black & Decker Disability Plan, providing supporting letters from his treating physicians, Dr. Hartman and the orthopedist.
- As part of its review, Black & Decker referred Nord to a neurologist, Dr. Antoine Mitri, for an independent examination.
- Dr. Mitri agreed with the diagnosis but concluded that Nord was capable of performing sedentary work with some interruptions.
- Relying in part on Dr. Mitri's opinion, MetLife, the claims processor, recommended denying the claim, and Black & Decker, the plan administrator, accepted the recommendation and denied Nord's benefits.
Procedural Posture:
- Kenneth L. Nord filed an action in the U.S. District Court against the Black & Decker Disability Plan to recover benefits.
- On cross-motions for summary judgment, the District Court granted judgment in favor of the Plan.
- Nord, as the appellant, appealed the decision to the U.S. Court of Appeals for the Ninth Circuit.
- The Ninth Circuit reversed the District Court's judgment, applied a 'treating physician rule,' and granted summary judgment in favor of Nord.
- The Black & Decker Disability Plan, as the petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the Employee Retirement Income Security Act of 1974 (ERISA) require that plan administrators apply a 'treating physician rule' that gives special deference to the opinions of a claimant's treating physician when evaluating a claim for disability benefits?
Opinions:
Majority - Justice Ginsburg
No. ERISA does not require plan administrators to accord special deference to the opinions of treating physicians. Unlike the Social Security system where the 'treating physician rule' is codified in regulations to promote uniformity in a massive, nationwide public benefits program, ERISA is designed to provide employers with flexibility in designing and administering their private, voluntary benefit plans. The text of ERISA and the regulations promulgated by the Secretary of Labor are silent on this issue, containing no provision that suggests treating physicians' opinions must be given special weight or that administrators face a heightened burden of explanation when rejecting such opinions. The Secretary of Labor has not adopted such a rule, and courts have no warrant to create one through federal common law, especially when critical differences exist between the statutory schemes of Social Security and ERISA. While plan administrators may not arbitrarily refuse to credit reliable evidence, they are not required to automatically favor a treating physician's evaluation over other conflicting, reliable evidence.
Analysis:
This decision clarifies that the procedural and evidentiary rules developed for Social Security disability claims do not automatically apply to ERISA-governed disability plans. By rejecting the 'treating physician rule' in the ERISA context, the Court reinforced the discretion of plan administrators and prevented the judicial imposition of rules not contemplated by the statute or its regulating agency, the Department of Labor. This holding increases the burden on claimants, who cannot rely on their treating physician's opinion as presumptively controlling, and gives plan administrators more leeway to rely on the opinions of their own consulting experts, provided their overall decision is not arbitrary and capricious.
