Burrell v. Metropolitan Life Insurance Co.
A magistrate of the Western District of Texas held that an employer was entitled to summary judgment on an employee's claim for short-term disability benefits because such benefit was a payroll benefit and not subject to ERISA, and the insured was not entitled to long-term disability benefits where the insurer did not abuse its discretion under ERISA in determining the insured was not disabled based on substantial evidence.
disability insurance policy, ERISA, short-term disability, payroll practice exemption, long-term disability, discretion of plan administrator, substantial evidence
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