Employee Retirement Income Security Act

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7^th Circuit Court of Appeals

Case Name: Jeffery Lane v. Structural Iron Workers Local No. 1 Pension Trust

Case No.: 22-1149

Officials: Flaum, Scudder, and Kirsch, Circuit Judges.

Focus: Employee Retirement Income Security Act

The eligibility for disability payments from the Fund is determined by the number of credits an ironworker has earned, with each credit representing 1,000 hours of work on union jobs in a given year. Individuals with more than five but fewer than 15 credits are entitled to disability benefits if they can demonstrate that they are “totally and permanently disabled as a result of an accident sustained while on the job and employed by a Contributing Employer.” In this case, Lane, an ironworker with nine credits, applied for disability benefits and was approved for Social Security Disability Insurance. However, the Fund’s Administrator requested additional information to establish a connection between Lane’s disability and an on-the-job injury. Lane provided medical records documenting injuries to his shoulder and knee, but none of them directly linked his disability to the specific accident in May 2014. Lane acknowledged that his Social Security Disability Insurance award was based on a combination of factors, not solely the 2014 accident. A letter from Lane’s physician mentioned several work-related injuries without specifying the corresponding events or whether those injuries were the sole basis for Lane’s disability award from the Social Security Administration.

Following a review by the Medical Review Institute of America, which concluded that the records did not establish a connection between Lane’s Social Security Administration disability and the 2014 accident, the Fund’s Trustees upheld the denial of Lane’s claim. The Seventh Circuit court affirmed the summary judgment in favor of the Fund under the Employee Retirement Income Security Act, 29 U.S.C. 1002, describing the denial as “not outright unreasonable.”

Affirmed.

Decided 07/17/23

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