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The Plan specifically sets forth the requirements Ms. Wolf needed to meet in

order to receive benefits31. Nowhere in the Plan is there a requirement that objective

medical evidence needs to be submitted before benefits can be paid. Notwithstanding

this fact, Delta required the submission of objective evidence to show that Ms. Wolf was

disabled under the terms of the Plan32. The insertion of an additional term shows how the

conflict of interest influenced Delta’s interpretation. Delta’s interpretation cannot be

upheld due to its conflict of interest and would be unreasonable under even the most

deferential standard.

“A second interpretive principle guiding our analysis is that pension plan trustees or administrators may not construe a plan so as to impose an additional requirement for eligibility that clashes with the terms of the plan. Lower federal courts have held that where plan trustees ‘impose a standard [of eligibility for pension plan benefits] not required by the pension plan itself,’ that action ‘results in an unwarranted and arbitrary construction of the plan’.

... Recently, in Saffle, we extended this principle to disability benefits. In Saffle, a plan administrator denied an employee long-term benefits for ‘total disability.’ The administrator concluded that the employee did not satisfy the definition of ‘total disability’ because medical reports concluded the employee could return to work if her job was modified to allow her to perform exclusively sedentary work. On appeal, we rejected the administrator’s interpretation of the disability plan in part because the administrator construed the plan to prohibit benefits if the employee was able to continue working with ‘accommodations.’ Such an interpretation, we concluded, would operate to ‘impose [ ] a new requirement for coverage’: it would require the claimant to show that accommodations were futile. We rejected this implied additional term, explaining that a ‘[plan] administrator lacks discretion to rewrite the plan.’”

Canseco, 93 F.3d at 608-9 (citations omitted).

In addition to inserting an addition requirement to determine eligibility, Delta

interpreted the terms “disabled” and “work” unreasonably, effectively making the Plan

31 32

Plan § 4.03. See, Exhibits D, H, and N, discussed and explained



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