Black & Decker Disability Plan v. Nord, 538 U.S. 822 (2003)

Kenneth L. Nord was employed by a Black & Decker subsidiary as a material planner in a job classified as “sedentary” because it required up to six hours of sitting and two hours of standing or walking per day. Nord consulted with a physician about hip and back pain from which he had been suffering, and the physician diagnosed a “mild degenerative disc disease.” Nord submitted a claim form for disability benefits under the Plan, but the claim was denied. Nord then sought review of the denial of the claim, and Black & Decker referred Nord to a neurologist for an independent examination. Although the neurologist agreed with the diagnosis, she concluded that with the aid of pain medication, Nord was not disabled. Seeking to overturn the denial of the claim, Nord filed a lawsuit against the Black & Decker Disability Plan, an ERISA-governed employee welfare benefit plan. Although the district court concluded that the Plan’s denial of Nord’s claim was not an abuse of the plan administrator’s discretion, the Ninth Circuit reversed the judgment and ordered that judgment be entered in favor of Nord on the ground that the Plan had not provided adequate justification for rejecting the opinions held by Nord’s treating physicians. The United States Supreme Court vacated the judgment of the Ninth Circuit, holding that the court had erroneously applied the “treating physician rule” in the ERISA context.