Cerentano v. UMWA Health & Retirement Funds

From 1978 to 2000, Cerentano worked as a coal miner. He was injured in 15 mining incidents and received six separate awards of permanent partial disability, but was able to return to work after each injury. In 2000 Cerentano was wrongfully discharged after a false positive drug test. Months later, he was diagnosed with depression due to his firing and treated for dysthymia and anxiety. Eventually, Cerentano found work as a real estate agent and a vehicle transporter. In 2005, Cerentano’s car was hit, causing more injuries. Cerentano was awarded Social Security disability benefits. He was denied disability pension benefits under the United Mine Workers Pension Trust Plan, based on the trustees’ conclusion that there was no causal link between his mine injuries and the award of Social Security benefits. Cerentano sued under the Employee Retirement Income Security Act, 29 U.S.C. 1332(a)(1)(b). The district court granted summary judgment to the plan. The Seventh Circuit reversed and remanded. The trustees should have examined all of the injuries, severe and non‐severe, that the ALJ relied on in finding Cerentano disabled and should have determined which of those injuries were caused by mine accidents and whether, the mine‐related injuries, in combination, comprised “a causal link.” View "Cerentano v. UMWA Health & Retirement Funds" on Justia Law