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Evans v. Capital Blue Cross

Pennsylvania Superior Court

January 5, 2022

The Pennsylvania Commonwealth Court reversed the trial court’s order, which granted summary judgment. Capital Blue Cross (“CBC”) employed Evans. CBC provided its employees with short-term disability benefits under its Salary Continuation Benefit Plan (“the Program”), which was described in a summary plan description (“SPD”). Evans timely applied for shortterm disability benefits under the Program, and the claims evaluator — Hartford — approved the payment of benefits to her from her disability onset date of March 9, 2016, through May 26, 2016. Thereafter, Hartford informed Evans that the benefits under the Program were not payable to her. After Evans’s short-term disability benefits were terminated and CBC denied her appeal, she filed a complaint against CBC, asserting claims for breach of contract and violation of the Pennsylvania Wage Payment and Collection Law (“WPCL”). CBC filed a motion for summary judgment, arguing that Evans could not establish the existence of an express or implied contract. The trial court granted CBC’s motion, and the Superior Court reversed. The Court ruled that the terms and conditions of the SPD constituted a unilateral offer of employment, which Evans accepted by continuing the performance of her duties. A  reasonable person in Evans’s position would understand that her continued performance would obligate CBC to provide her with shortterm disability benefits if she met the terms and conditions of the Program. Therefore, the trial court erred when it determined that no contract for short-term disability benefits existed between Evans and CBC. Whether Evans met the terms and conditions of the Program — specifically, if she could have returned to work for another employer after May 26, 2016 — was a question of fact that the parties disputed.

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