Tenth Circuit Upholds Plan’s Decision to Deny Disability Benefits for Employment-Related Stress

Fite v. Bayer Corporation, No. 13-7027 (10th Cir. 2014).
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Bayer Corporation maintained a short-term disability plan. The plan capped benefits at 26 weeks and explicitly excluded coverage for “disabilities resulting from … [e]mployment-related mental or emotional disabilities.” The plan’s third-party administrator was responsible for performing the initial benefits determination and the first-level review of denials of benefits. Bayer’s benefits committee retained responsibility for deciding final appeals.

Margie Fite took a leave of absence from her position as a pharmaceutical representative with Bayer Corporation. In June 2009 she applied for and was granted short-term disability benefits on the basis of a psychologist’s diagnosis of major depressive disorder and generalized anxiety disorder. Read More →