Risk That Plan Participant Would Relapse Into Addiction If He Returned To His Job Did Not Constitute A Disability
In this case, the 4th Circuit held that an ERISA long-term disability plan administrator did not abuse its discretion in concluding that the risk that a plan participant would relapse into his addiction to an anesthetic drug if he returned to his work as a nurse anesthetist did not constitute a disability under the terms of the benefit plan.
Under the terms of the plan, a
disability was an injury or sickness causing physical or mental impairment to
such a degree of severity that the participant was continuously unable to
perform the material and substantial duties of his regular occupation. Although
the participant's license had been restricted by the state Board of Nursing, so
as to prohibit him from having access to narcotics or working as a certified
registered nurse anesthetist, the participant was physically and mentally
capable of performing his old job.
Stanford v.
Continental Cas. Co.
The 4th Circuit Court of Appeals’ jurisdiction includes Maryland, North Carolina, South Carolina, Virginia and West Virginia.