DALLAS, TX – April 13, 2021 -Dallas attorneys Matthew Kolodoski, Gino Rossini, and Harrison Yoss recently prevailed on behalf of their clients, an appellee insurer and claims administrator for an ERISA plan, before the U.S. Court of Appeals for the Fifth Circuit. The appellant sued for plan benefits, arguing that accidental death benefits were improperly denied under the plan's Medical or Surgical Treatment Exclusion during the administrative review and that the U.S. District Court for the Southern District of Texas improperly upheld the denial of benefits.
Relying on various dictionary definitions, the Fifth Circuit first held that the phrase "medical treatment" is unambiguous and has a generally accepted meaning, despite it not being defined within the plan documents. Additionally, the Fifth Circuit rejected the appellant's argument that "medical treatment" was limited to only a physician's actions and not actions carried out at a physician's direction. It held that "the phrase [medical treatment] does not turn on who is providing the treatment." Accordingly, the Fifth Circuit affirmed the district court's judgment upholding the denial of accidental death benefits. The underlying case was pending before the U.S. District Court for the Southern District of Texas, Houston Division, and the case was appealed to the U.S. Court of Appeals for the Fifth Circuit.
A PDF of the Thompson Reuters analysis is available here.