No Abuse of Discretion Where Plan Fails to Consider Plaintiff’s Salary in “Any Occ” Benefits Determination

A participant in an ERISA plan became disabled and filed a claim for LTD benefits. After paying benefits for 18 months under the “own occupation” definition of disability, the Plan reviewed the participant’s claim under the “any occupation” standard. The “any occupation” definition required an examination as to whether the participant could perform any job for which she was “qualified by training, education, or experience.” After determining that the participant could work in any number of sedentary occupations, the administrator terminated her claim for further LTD benefits. The participant asserted that administrator’s claim determination was an abuse of discretion because the “any occupation” language included an implicit requirement that the administrator consider her salary or station in life when making a disability determination. The court ruled that there was no such requirement and upheld the administrator’s claim determination.