“Undisputed Disability” – Fourth Circuit Confirms Summary Judgment Standard in ERISA Benefit Disputes
Commentary on Rebecca Wonsang v. Reliance Standard Life Insurance Company, No. 24-1419 (4th Cir. June 13 2025)

1. Introduction

Rebecca Wonsang, a former physical therapist assistant, sought long-term disability benefits under an employer-sponsored policy governed by the Employee Retirement Income Security Act of 1974 (ERISA). Reliance Standard Life Insurance Company, both insurer and plan fiduciary, initially paid but later terminated benefits. When the company neither timely ruled on Wonsang’s administrative appeal nor adequately addressed her treating physicians’ opinions, she sued in the Eastern District of Virginia.

The District Court granted her summary judgment. On appeal, the Fourth Circuit affirmed, holding that where the evidentiary record shows no genuine dispute of material fact regarding disability, a trial court may enter summary judgment even in an ERISA denial-of-benefits suit—regardless of whether review is de novo or under the deferential “abuse-of-discretion” standard. The court also declined to remand to the insurer to consider a policy limitation invoked for the first time in litigation, branding remand “futile.”

2. Summary of the Judgment

• Procedural Posture: Appeal from summary judgment for the claimant; insurer alleged factual disputes and requested remand.
• Holdings: (1) Summary judgment was proper because material facts were undisputed; (2) Insurer’s decision was arbitrary even under abuse-of-discretion review; (3) Remand to apply a “Self-Reported Conditions Limitation” would be pointless given objective MRI evidence.
• Disposition: District court’s judgment affirmed. One judge dissented, urging a bench trial under Fed. R. Civ. P. 52.

3. Detailed Analysis

3.1 Precedents Cited and Their Influence

• Tekmen v. Reliance Standard Life Ins. Co., 55 F.4th 951 (4th Cir. 2022)
  Clarified when district courts should move from summary judgment to a Rule 52 bench trial in ERISA cases. The majority distinguished Tekmen, finding the factual record here “uncontested,” hence summary judgment sufficed.
• Black & Decker Disability Plan v. Nord, 538 U.S. 822 (2003)
  Rejected mandatory treating-physician deference. The court relied on Nord to note that, while no “treating-physician rule” exists, plan administrators must still address contrary medical evidence.
• Smith v. Cox Enterprises Welfare Benefits Plan, 127 F.4th 541 (4th Cir. 2025)
  Recently emphasized “deliberate, principled reasoning” and duty to confront conflicting evidence. The panel applied this standard in faulting Reliance for ignoring MRIs and doctors’ reports.
• DuPerry v. Life Ins. Co. of N. Am., 632 F.3d 860 (4th Cir. 2011)
  Quoted to show that sporadic activities do not equate to vocational capacity; used to reject Reliance’s reliance on the claimant’s blogging and book writing.
• Gagliano v. Reliance Standard Life Ins. Co., 547 F.3d 230 (4th Cir. 2008)
  Addresses judicial authority to enforce plan terms. Reliance cited it to seek remand, but the panel found remand unwarranted.
• Quesinberry v. Life Ins. Co. of N. Am., 987 F.2d 1017 (4th Cir. 1993)
  Sets “exceptional circumstances” standard for supplementing the record on appeal. The majority refused to admit a late vocational report under this rule.

3.2 Court’s Legal Reasoning

1. Standard of Review Toggled but Ultimately Irrelevant.
   • District court adopted de novo review, finding Reliance forfeited discretion by missing ERISA’s 45-day appeal deadline.
   • Fourth Circuit chose not to resolve that legal question, holding that Reliance’s decision fails even under the more lenient abuse-of-discretion test. This pragmatic move avoided creating new forfeiture doctrine yet secured the claimant’s victory.
2. Undisputed Medical Evidence.
   All physicians—both treating and even Reliance’s in-house nurse—consistently documented cervical disc herniation, spinal instability, debilitating fatigue, and inability to sustain work. MRI scans provided objective corroboration. Reliance’s selective quotation from records did not create a genuine dispute.
3. Sifting vs. Cherry-Picking.
   The panel stressed that plan fiduciaries may disagree but cannot “cherry-pick” favorable snippets while ignoring adverse findings. This echoes the emerging “holistic review” expectation in ERISA jurisprudence.
4. Futility of Remand.
   Because MRIs are “standard medical procedures,” the Self-Reported Conditions Limitation (24-month cap on unverifiable symptoms) could not plausibly defeat coverage. Remand would waste judicial and party resources—contrary to DuPerry’s “no purpose” principle.
5. Procedural Integrity Over Outcome.
   The court implicitly warned administrators: missing statutory deadlines or raising new limitations late in litigation risks losing deference and relief.

3.3 Potential Impact

• “Undisputed Disability Doctrine.” The decision signals that where objective medical evidence is one-sided, district courts may resolve ERISA cases at summary judgment without convening a Rule 52 trial, streamlining litigation.
• Heightened Duty to Address Medical Imaging. Administrators must grapple with MRIs and other objective diagnostics; silence may constitute arbitrary decision-making.
• Strategic Timing of Policy Limitations. Insurers who withhold contract defenses (e.g., self-reported limitations) during administrative review risk waiving them, because courts may deem remand futile.
• Procedural Non-Compliance Consequences. Although unresolved here, the panel’s willingness to consider forfeiture of discretion underlines the urgency for ERISA fiduciaries to respect statutory timelines.
• Increased Predictability for Claimants. Claimants with strong objective evidence might expect swifter judicial relief, discouraging insurers from protracted litigation tactics.

4. Complex Concepts Simplified

• ERISA: A federal law setting minimum standards for employer-sponsored benefit plans and giving courts authority to review benefit denials.
• Abuse-of-Discretion Review: A deferential standard: courts uphold the administrator’s decision if “reasonable.” Requires less evidence for the plan to prevail.
• De Novo Review: The court decides the issue afresh, giving no deference to the plan administrator.
• Self-Reported Conditions Limitation: Policy clause limiting benefits for ailments diagnosed solely on subjective reports (e.g., pain, fatigue) without objective tests.
• Remand (ERISA context): Sending the case back to the administrator for further review, often ordered when procedures were flawed but additional fact-finding may cure the defect.
• Rule 52 Bench Trial: A non-jury trial where the judge resolves disputed facts and applies the law.

5. Conclusion

Wonsang v. Reliance Standard crystallizes a practical rule: where an ERISA record contains uncontroverted objective evidence of disability, courts may grant summary judgment for claimants notwithstanding reservation of discretionary authority in the plan. Administrators must confront, not selectively ignore, unfavorable medical data, and cannot expect remand to salvage defenses raised belatedly. The decision fortifies procedural rigor and evidentiary candor in ERISA benefit determinations, offering clear guidance to both litigants and lower courts moving forward.