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ALEX AUTRAN, administrator of the estate of Jean-Philippe
Autran,
Plaintiff-Appellant,
v.
PROCTER & GAMBLE HEALTH AND LONG-TERM DISABILITY
BENEFIT PLAN, c/o Procter & Gamble Disability
Committee; PROCTER & GAMBLE DISABILITY COMMITTEE,
in its capacity as the Plan Administrator and/or Trustee for
the Procter & Gamble Disability Benefit Trust,
Defendants-Appellees. |
No. 20-6432 |
Appeal from the United States District Court for the Eastern District of Tennessee at Knoxville.
No. 3:19-cv-00135—Clifton Leland Corker, District Judge.
Argued: October 20, 2021
Decided and Filed: February 24, 2022
Before: BOGGS, GRIFFIN, and MURPHY, Circuit Judges.
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OPINION
_________________________
MURPHY, Circuit Judge. A seizure disorder unfortunately ended Dr. Jean-Philippe
Autran’s career as a top-notch research scientist with Procter & Gamble. In the ensuing years,
Autran received total-disability benefits under the Procter & Gamble Health and Long-Term
Disability Plan (the “Plan”). The Procter & Gamble Disability Committee (the “Committee”)
later terminated these benefits after concluding that Autran no longer qualified as totally disabled
within the meaning of the Plan. Autran sued to overturn the Committee’s benefits decision under
the Employee Retirement Income Security Act (ERISA). Yet the Plan delegates discretionary
authority to the Committee to decide benefits claims, so we must review its decision under the
deferential arbitrary-and-capricious test. And the Committee had rational reasons to depart from
the earlier total-disability finding. Among other new evidence, a doctor who performed many
objective tests on Autran for over six hours found no basis to conclude that he suffered from a
debilitating condition. We thus affirm the district court’s summary-judgment decision for the
Committee. |
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