In the case of State ex rel. Sanderlin v. State Teachers Retirement Sys., the Magistrate upheld the State Teachers Retirement System (“STRS”) decision to terminate Relator’s disability benefits upon an evidentiary finding that Relator is no longer permanently disabled.
Here, Relator was granted disability benefits in 2002 after an STRS finding that Relator suffered from debilitating psychiatric conditions. Relator was evaluated on a continuing basis for approximately eighteen years. In 2021, a psychiatric evaluation revealed that Relator was able to maintain alternative employment and that her “mental condition” did not hinder her ability to work. As a result, the STRS terminated Relator’s disability benefits, and Relator timely appealed the STRS decision.
Relator argues that the psychiatric evaluation was not conclusive, nor was it admissible for submission to the STRS board pursuant to Federal case law. The STRS Board asserts that their decision to apply the psychiatric evaluation was an appropriate means to determine whether Relator requires continued receipt of disability benefits. The Magistrate agreed with the STRS and upheld the board decision.
In support of this decision, the Magistrate reasoned that the psychiatric evaluation alone was enough evidence to support the STRS’s board decision. In further support of this decision, the STRS Medical Review Board comprised of medical physicians that independently reviewed the Relator’s file had recommended that disability benefits be terminated. To Relator’s second argument, the Magistrate held that the federal regulations under the Employee Retirement Income Security Act of 1974, (“ERISA”) are inapplicable to STRS board proceedings.
To read this case, click here.
Authors: Matthew John Markling and the McGown & Markling Team.
Note: This blog entry does not constitute – nor does it contain – legal advice. Legal jurisprudence is like the always-changing Midwestern weather. As a result, this single blog entry cannot substitute for consultation with a McGown & Markling attorney. If legal advice is needed with respect to a specific factual situation, please feel free to contact a McGown & Markling attorney.