Employment – disability

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United States Court of Appeals For the Seventh Circuit

Civil

Employment – disability — ERISA

Where a trustee failed to consider that mine accidents contributed to an employee’s disability, the denial of benefits is reversed.

“In sum, the trustees should have examined all of the injuries—both severe and non-severe—that the ALJ relied on in finding Cerentano disabled. The trustees also should have determined which of those injuries were caused by mine accidents and whether, in combination, those mine-related injuries comprised ‘a causal link’ in the ALJ’s award of disability benefits. Of course, we do not answer these questions here. We merely remand to the trustees to address these issues in a new round of review. See Holmstrom, 615 F.3d at 778 (‘When an ERISA plan administrator’s benefits decision has been arbitrary, the most common remedy is a remand for a fresh administrative decision rather than an outright award of benefits … .’).”

Reversed and Remanded.

13-2037 Cerentano v. UMWA Health and Retirement Funds

Appeal from the United States District Court for the Southern District of Illinois, Reagan, J., Flaum, J.