ST. LOUIS – The U.S. District Court for the Eastern District of Missouri has denied a Wells Fargo employee's motion for summary judgment relating to the denial of her short-term disability request by the company's claims administrator.
The court rejected the plaintiff's argument and ruled that Liberty Life Assurance Co. of Boston's decision "was reasonable given the evidence before it" and that there was no requirement for the plan administrator to obtain a "vocational consultant" based on case law.
The court's order was entered by U.S. District Judge Charles Shaw.
According to the March 6 court filing, Jane Moldovan, a Wells Fargo project manager, began working for the bank in November 2008. In June of 2017, Moldovan filed a claim for the company's short-term disability plan (STD) due to experiencing several health problems such as chronic fatigue, menopausal issues, insomnia, hypothyroidism and persistent mood affective disorders. Moldovan submitted her primary care doctor's notes with her claim, which stated her symptoms were related to "chronic life stress and her current work environment," according to Shaw's order. The doctor recommended Moldovan take a leave from work because of "increased stress and emotional trauma from work" impacting her health, the order states.
In August 2017, Liberty, Wells Fargo STD claims administrator, denied Moldovan's claim and determined her benefits "were not payable" based on a review of the claim by a Liberty nurse case manager that stated: "Restriction and limitations are not supported as of July 1, 2017, as file has no evidence of a mental status exam, abnormal lab work or abnormal physical exam," according to the order.
The plaintiff appealed her STD denial and provided additional documentation, including some test results and notes from two other medical providers confirming her original health issues. Liberty denied the appeal, stating "in the absence of sufficient clinical evidence to support your inability to perform the activities consistent with those required to perform your job" that Moldovan did not meet "definition of disability," the order states.
Moldovan filed a court action in March 2018 arguing Liberty abused its discretion because the company's reasoning was not factually correct or "not based on the plan's requirements" and that Liberty had no evidence to contradict her medical issues, especially by a nurse who had never examined Moldovan or obtained a "vocational evaluation," the order states.