Salley v. E.I. Dupont de Nemours & Co.
5th Circuit
966 F.2d 1011 (5th Cir. 1992)
Danielle Salley (plaintiff), covered under her father Jack's (plaintiff) ERISA benefits plan through Dupont (defendant), was repeatedly hospitalized for emotional disabilities; her treating psychiatrist, Dr. Blundell, believed she had stabilized but should not be released until a suitable treatment plan was identified. Dupont's case manager, Dr. Ahluwalia, relied on Blundell's finding that Danielle had stabilized but disregarded his caution about premature release, terminated her benefits without examining Danielle or reviewing her later hospitalization records, and Dupont adopted that determination. The district court found Dupont abused its discretion in terminating benefits, and Dupont appealed.
Whether, in determining eligibility for benefits under ERISA, an employer's failure to consider a treating physician's advice without conducting an independent investigation constitutes an abuse of discretion.