ERISA Factual Disputes Require Bench Trials, Appeals Court Says

Reliance Standard Life Insurance Co. owes disability benefits to a financial analyst with hypersensitivity to light and noise, the Fourth Circuit said Friday in an opinion analyzing a circuit split on how courts resolve benefit disputes under ERISA.

When cases challenging a denial of benefits under the Employee Retirement Income Security Act involve disputed facts, they should be resolved through a judge-only bench trial based on the administrative record, the US Court of Appeals for the Fourth Circuit unanimously ruled.

In so doing, the court specifically rejected the “quasi-summary-judgment procedure” used by the First and Tenth circuits, which involves ...