An Illinois district court, after remand by the Seventh Circuit, recognized that CIGNA’s disregard of an ERISA claimant’s award of SSDI benefits, after providing an advocate to the long term disability claimant to secure the same, added weight to the notion that CIGNA was operating under a conflict of interest. The court however, distinguished the case from others because the claimant had been denied SSDI benefits twice before being approved months later, and because CIGNA performed an independent medical evaluation which the court believed reflected “safeguard procedures to minimize conflict.” Thus, instead of overturning CIGNA’s long term disability claim determination as being influenced by its conflict of interest, the court simply remanded the case back to CIGNA for explanation of its disagreement with the SSA’s decision, as failure to provide such explanation was inconsistent with ERISA’s requirement that specific and understandable reasons be communicated for denial. Raybourne v. CIGNA, February 8, 2010
