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Sixth Circuit overturns judge's dismissal of woman's long-term disability claim

Laura Waskiewicz was a 20 year employee of Ford Motor Company when she attempted to draw upon the Salaried Disability Plan.  Her claim was denied based on the suggestion that she "was no longer an employee" when she applied.  She had suffered a "debilitating emotional breakdown" on her last day of work, October 25, 2010, and was fired for missing five consecutive days of work.  The trial judge sustained the Plan's decision that having been fired for failing to inform Ford of her disability within five days, Waskiewicz was properly terminated from employment and therefore not an employee eligible to collect disability payments.

To their credit, the federal appeals judges recognized the absurdity of this result and reversed it.  They noted that Waskiewicz's doctor confirmed her disability in November and that she was "catatonic" when she was required to comply with the "five day quit" rule.  The Court noted that it was legally obligated to uphold all disability plan decisions that are not "arbitrary or capricious," but felt compelled to reject Ford's disability defense.  It noted that this standard on appeal did not "require federal courts to rubber-stamp decisions by plan administrators that fly in the face of a participant's legitimate expectation." 

The Court noted that the plan's decision to deny benefits to an employee who was incapable of complying with termination provisions, because of the very disability for which she sought coverage, was "inconsistent with the spirit of employer-provided health care benefits."  Reading the policy as the plan applied it "would be an abuse of discretion" and "arbitrary."

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