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5th Circuit: No Plan Administrator Duty to Investigate Authenticity of Emails Relied Upon in Making Benefit Determination

A plan administrator denied disability benefits to a participant, and sought reimbursement for previously paid benefits, after the administrator concluded that the participant was not in fact disabled.?á The administrator?ÇÖs decision rested in large part on emails provided by the participant?ÇÖs ex-boyfriend that showed the participant was not disabled.?á The participant argued that the administrator abused its discretion in considering the emails without confirming their authenticity.?á The U.S. 5th Circuit Court of Appeals, whose jurisdiction includes Texas, held that a plan administrator does not have a duty to reasonably investigate a claim or to investigate the accuracy or source of evidence because the claimant, who is likely in a better position to produce contradictory evidence, should submit evidence discrediting the evidence that the administrator relied upon in making its determination.?á Here, the participant argued that email accounts can easily be hacked and/or forged, but produced no evidence that the emails, which appeared to be authentic, were actually hacked or forged.

Truitt v. Unum Life Ins. Co. of Am., No. 12-50142 (5th Cir. Sept. 6, 2013).

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October 2013