Dutkewych v. Std. Ins. Co.

In this 2015 ERISA case, there was substantial evidence that plaintiff’s mental illness, whether or not related to chronic Lyme disease, contributed to his disability as of June 2011 where reports from plaintiff’s own treating physicians established that he had ongoing mental disabilities, in addition to his physical symptoms, as of the period around June, 2011. The plan administrator’s interpretation of the Mental Disability Limitation and the Rules governing its application was by no means unreasonable and so must prevail. The plan administrator’s limitation of the plaintiff’s benefits to 24 months was not arbitrary or capricious given the substantial evidence in the record that mental disorders, regardless of their cause, contributed to his disability as of June 1, 2011.

Judgment affirmed.

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