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Labella v. PNC Bank Corp.

United States District Court, E.D. Pennsylvania

February 26, 2014

ROXANNE LABELLA, Plaintiff,
v.
THE PNC BANK CORP. AND AFFILIATES LONG TERM DISABILITY PLAN Defendant.

MEMORANDUM

C. DARNELL JONES, II, District Judge.

I. Introduction

Plaintiff Roxanne Labella brings the above-captioned action against Defendant PNC Bank Corp. and Affiliates Long Term Disability Plan, alleging that Defendant violated ERISA by denying her application for Long-Term Disability ("LTD") benefits. Now pending before this Court are cross motions for summary judgment. Plaintiff contends Defendant's denial of LTD benefits was arbitrary and capricious, while Defendant maintains Plaintiff failed to timely submit her claim and that LTD benefits were properly denied. For the reasons set forth below, Defendant's Motion shall be granted and Plaintiff's motion shall be denied.

II. Factual Background

Plaintiff was employed by PNC Bank as a Loan Support Analyst II from August 10, 2009 until August 13, 2010. (Def.'s Stmt. Undisp. Facts ¶ 1; Pl.'s Stmt. Undisp. Facts ¶ 1). As an employee of PNC, Plaintiff participated in The PNC Bank Corp. and Affiliates Long Term Disability Plan ("Plan"). The Plan is an employee welfare benefit plan governed by the Employee Retirement Income Security Act ("ERISA") and provides long-term disability benefits to qualifying employees. (Def.'s Stmt. Undisp. Facts ¶ 2; Pl.'s Stmt. Undisp. Facts ¶ 2). Within the Plan, PNC is listed as the Plan Administrator and as such, has the power to do the following:

1) To establish and enforce such rules, regulations and procedures as it shall deem necessary and proper for the efficient operation and administration of the Plan;
2) To interpret the Plan, and the rules and regulations, including the supplying of any omissions in accordance with the intent of the Plan and its interpretations thereof in good faith;
3) To determine the eligibility and status of any Employee with respect to Plan participation;
4) To determine questions of fact, law, and mixed questions of fact and law;
5) To compare and calculate for payment the amount of benefits payable to any person in accordance with the terms of the Plan; and
6) To appoint or employ individuals or firms to assist in the administration of the Plan and any other agent or agents it deems advisable.

(Def.'s Stmt. Undisp. Facts ¶ 4). The Plan also provides that "[t]he Administrator shall have complete and sole discretion with respect to each of the powers listed in subparagraphs (1)-(6) above and no decision of the Administrator shall be overturned unless the decision is arbitrary and capricious." (Def.'s Stmt. Undisp. Facts ¶ 5).

Under the Plan, the terms "Total Disability" and "Totally Disabled" require that, for the first twenty-four (24) months of Total Disability (including an initial ninety-day (90) Elimination Period), the Participant "cannot perform each of the material duties of his or her regular occupation" because of injury or sickness, and "requires the regular attendance of a physician." (Def.'s Stmt. Undisp. Facts ¶ 10). The Elimination Period is defined as "[a] period of consecutive days of Total Disability for which no benefit is payable." (Def.'s Stmt. Undisp. Facts ¶ 11). "The Elimination Period is shown in the Plan Specifications and begins on the first day of Total Disability." ( Id. ) "If during the Elimination Period Total Disability stops for any seven (7) (or fewer) calendar days, then the Total Disability will be treated as continuous. However, days that the Participant is not Totally Disabled will not count toward the Elimination Period." ( Id. )

LTD benefits paid under the Plan cease: on the earliest date Total Disability ceases; the date that the Participant fails to provide proof of Total Disability; or, the date that the Participant ceases employment. (Def.'s Stmt. Undisp. Facts ¶ 13). It is the Participant's responsibility to submit information sufficient to establish Total ...


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