Davis v. Metropolitan Atlanta Rapid Transit
| Decision Date | 02 March 2009 |
| Docket Number | No. A08A2080.,A08A2080. |
| Citation | 674 S.E.2d 627,296 Ga. App. 355 |
| Parties | DAVIS v. METROPOLITAN ATLANTA RAPID TRANSIT AUTHORITY. |
| Court | Georgia Court of Appeals |
Kenneth I.M. Behrman, Atlanta, for appellant.
LaShanda R. Dawkins, for appellee.
Appellant Thomas Davis filed this breach of contract action against his former employer, Metropolitan Atlanta Rapid Transit Authority d/b/a MARTA, alleging that the corporation had improperly reduced and terminated his long-term disability benefits. MARTA filed a motion for summary judgment, asserting that its actions were authorized under the Mass Transit Integrated Risk Master Policy issued by ACE Indemnity Insurance Company, which contained the complete terms and limitations governing the payment of benefits. Davis filed a motion in limine and a motion for partial summary judgment, alleging that the additional terms set forth in the Master Policy were irrelevant to his claim and that the payment of benefits was instead controlled by MARTA's open enrollment booklet, which failed to provide the limitations upon which MARTA relied. The trial court concluded that the open enrollment booklet did not set forth the complete terms governing the benefits, but rather provided adequate notice that complete information had to be obtained from another source, i.e., the Schedule of Benefits under the Master Policy, the terms of which authorized MARTA's actions. Based upon these conclusions, the trial court denied Davis's motions and granted MARTA's motion concerning this issue. Davis appeals the trial court's rulings. For the reasons that follow, we affirm.
Lau's Corp. v. Haskins, 261 Ga. 491, 405 S.E.2d 474 (1991).
In this case, the undisputed facts and evidence established that Davis started working for MARTA in 1998. On June 21, 2002, Davis became disabled due to a mental illness and began receiving short-term disability benefits. After his entitlement to short-term disability benefits was exhausted, Davis applied for and was approved to receive long-term disability benefits, effective September 21, 2002.
MARTA provided eligible employees with basic long-term disability coverage equal to 60% of the employee's base pay up to a maximum of $7,000 per month, payable if the employee became disabled due to an occupational or non-occupational injury, illness, or condition. MARTA's open enrollment booklet "[c]ontain[ed][h]ighlights of [b]enefit [p]lans" and provided a "brief description[]" of the basic long-term disability benefits, with instructions that employees consult the Summary Plan Description "[f]or complete details about [the] benefits." The open enrollment booklet further advised that additional information could be viewed by accessing the Benefit system, and that the Benefits Office could be contacted to address any questions.
MARTA's long-term disability benefits to employees were provided through a combination of self-funding and insurance under the Master Policy issued by ACE Indemnity Insurance Company. The Master Policy contained a Disability Coverage Part and Schedule of Benefits that provided complete details, including definitions, limitations, exclusions, and instructions governing the payment of the benefits. The Schedule of Benefits contained a limitation on the payment of long-term disability benefits for certain conditions, and pertinently specified that "[o]nce 24 monthly [d]isability [b]enefits have been paid, no further benefits will be payable for . . . [m]ental [i]llness." Moreover, the Schedule of Benefits authorized MARTA to "reduce the [d]isability [b]enefits by the amount of . . . [o]ther [i]ncome [b]enefits . . . includ[ing] . . . any Social Security disability or retirement benefits" that the employee was entitled to receive and further authorized the recovery of any overpayment of benefits.
MARTA's claims administrator had several communications with Davis regarding the long-term disability benefits, and had informed him of the 24-month limitation and offset that applied to his claim. The Schedule of Benefits was kept at MARTA's Benefits Office and was available to employees upon their request. When Davis requested a copy of "the MARTA policy," the claims administrator sent him a copy of the Master Policy's Schedule of Benefits.
Beginning in January 2004, MARTA reduced Davis's long-term disability benefits by the amount of social security benefits he was receiving. MARTA also claimed that it had mistakenly overpaid Davis's benefits, and made monthly deductions from Davis's benefits checks until the overpayment was recovered. Finally, in September 2004, MARTA terminated its disability payments to Davis.
Davis filed suit against MARTA, alleging that it had breached its agreement under the open enrollment booklet to provide long-term disability benefits. Davis sought the payment of additional benefits and the return of the amounts that had previously been withheld as reductions and overpayments. The trial court granted summary judgment in favor of MARTA, ruling that Davis had adequate notice that the open enrollment booklet did not set forth the complete terms of MARTA's long-term disability benefits and that Davis had been provided with the Master Policy's Schedule of Benefits containing the detailed terms that authorized MARTA's actions. Davis appeals from this ruling, contending that his claim for long-term disability benefits was exclusively governed by the general terms in MARTA's open enrollment booklet. We disagree and conclude that the trial court's ruling was correct.
As stated in the trial court's order, this issue is controlled by the Supreme Court of Georgia's decision in Adams v. Hercules, Inc., 245 Ga. 464, 265 S.E.2d 781 (1980). In Adams, an employee filed suit to recover benefits allegedly owed under the company's voluntary supplemental payment plan. Although the company's master agreement contained a provision limiting the payment of the benefits, no such limitation was mentioned in the company's handbook delivered to newly hired employees. Based upon these...
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