7th Circ. Affirms Grant of Summary Judgment to AT&T in Disability Benefits Lawsuit

A three-panel judge of the U.S. Court of Appeals for the Seventh Circuit has affirmed the district court’s grant of summary judgment to AT&T amid claims of ERISA violations by a former employee. The case is In Craig Canter v. AT&T Umbrella Benefit Plan No. 3 et al., case number 21-1514. 

Craig Canter worked as a premises technician for Illinois Bell Telephone Co., a subsidiary of AT&T. His job involved installing wires, lifting heavy objects, and climbing ladders. After Canter began suffering from migraines, which caused lightheadedness and dizziness, he applied for short-term disability benefits through his employer in February 2017. Canter received benefits, and he was able to extend his disability leave multiple times. 

In July 2017, Canter received a denial of disability benefits after an independent medical reviewer determined that he was not disabled. His neurological test results showed no signs of impairment, and he reported improved symptoms. Canter appealed internally, additional testing came back normal, and he again received a denial of benefits. 

Canter returned to work in January 2018, but his employer sent him home because he did not have a doctor’s release to return to work. AT&T retroactively granted him unpaid leave through July 2018 and later extended that leave through January 2019. AT&T then terminated his employment because it could not accommodate his work restrictions. 

Canter filed suit against AT&T in November 2018, alleging various violations of ERISA. He claimed that the company had unlawfully revoked his disability benefits on a lack of evidence.

The district court granted summary judgment to AT&T in February 2021, finding that the company had sufficient evidence to discontinue Canter’s benefits. Plan documents clearly stated that a lack of medical evidence supporting the need for further disability benefits would result in the loss of those benefits. The findings of the independent medical reviewer, along with the repeated medical test results, were enough to support the conclusion that Canter was not disabled or entitled to benefits. The court also noted that Canter reported an improvement in symptoms, which added to the conclusion that Canter was not eligible for further disability benefits.

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