Lincoln National Disability Suit Revived; Circuit Split in Focus

An accounting manager on Friday revived his lawsuit seeking disability benefits from Lincoln National Life Insurance Co., according to an Eleventh Circuit opinion clarifying the circuit’s position on an ERISA issue that’s divided federal courts.

The district court that ruled against Virgil Harris wrongly refused to consider an affidavit and updated medical records that post-dated Lincoln’s decision terminating his benefits, the US Court of Appeals for the Eleventh Circuit held. While evidence outside the administrative record is typically excluded from ERISA cases in which plan administrators are entitled to judicial deference, that rule doesn’t extend to cases like Harris’, ...