Supreme Court of the United States

Black & Decker Disability Plan v. Nord

May 27, 2003538 U.S. 822

Summary

Justice Ginsburg delivered the unanimous opinion holding that ERISA does not require disability plan administrators to give special weight to treating physicians’ opinions or provide a distinct justification for crediting reliable contrary evidence. Administrators nevertheless may not arbitrarily disregard reliable evidence submitted by claimants. The Court explained that neither ERISA nor Labor Department regulations establish a treating physician rule and that differences between ERISA plans and Social Security counsel against judicially importing that program’s rule. It vacated the Ninth Circuit’s judgment and remanded without deciding other issues concerning Nord’s entitlement to benefits. There were no separate opinions.

Holding

  • Whether a treating physician rule governs disability determinations under ERISA plans.. Courts may not require ERISA plan administrators automatically to accord special weight to treating physicians’ opinions.
  • Whether rejecting a treating physician’s opinion triggers a distinct explanatory burden.. Courts may not impose a discrete burden of explanation when an ERISA plan administrator credits reliable evidence that conflicts with a treating physician’s evaluation, although administrators may not arbitrarily refuse to credit reliable claimant evidence.

Docket 02-469

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