Dennis Wible, acting as trustee for the estate of Marianne Wible, sought ERISA disability and life insurance benefits after Ms. Wible became unable to work due to systemic lupus erythematosus and related autoimmune complications. Medical records documented severe fatigue, joint pain, systemic involvement, and fluctuating symptoms characteristic of lupus, which impaired her ability to maintain regular employment.
Aetna denied benefits and disputed the severity and functional impact of Ms. Wible’s condition. The insurer relied on selective readings of the medical record and asserted that its decision was entitled to deferential review under discretionary plan language, seeking to limit the scope of judicial review.
The court rejected Aetna’s attempt to control the standard of review and held that de novo review applied. The ruling resolved a threshold issue that governed how the claim would be evaluated and ensured the court could independently assess the medical evidence supporting disability and benefit entitlement.
