Carlile v. Reliance Standard Life Ins. Co., 988 F.3d 1217 (10th Cir. Feb. 22, 2021)
This appeal arose from a dispute between an employee and an ERISA plan administrator over entitlement to long-term disability benefits. The relevant policy language provided coverage to an “active, Full-time employee” when the disability arose, but the administrator argued that the employee was not “active” because his termination was pending at the time of the disability. The Tenth Circuit agreed with the district court that the phrase “active Full-time employee” was ambiguous and that it should be construed in favor of the employee finding coverage.