answered with “three mistakes.” None of the three mistakes, however, commented on the IME results that Briggs had a sedentary functional capacity. Therefore, Liberty reasonably concluded that Dr. Anchor’s failure to comment suggested that he agreed with the IME’s conclusion that Briggs had a. sedentary capacity. Even considering the facts in the light most favorable to Briggs, this case amounts’to Briggs’s treating physicians and the non-treating physicians having conflicting clinical findings. Although Liberty cannot arbitrarily ignore the opinions of Briggs’s treating physicians, it reasonably may choose to value the opinions of its own medical consultants over his treating physician. Black & Decker Disability Plan v. Nord, 538 U.S. 822, 834, 123 S.Ct. 1965, 155 L.Ed.2d 1034 (2003) (<HOLDING>). Here, an independent medical examiner and an
recognizing that plan participants should be able to access information about the plan administrators fiduciary duties from the plan administrators counsel holding that plan administrators may credit reliable evidence that conflicts with a treating physicians evaluation but may not arbitrarily refuse to credit a claimants reliable evidence including the opinions of a treating physician holding that erisa does not require plan administrators to give special deference to treating physicians opinions although administrators may not arbitrarily refuse to credit them holding that courts have no warrant to require administrators automatically to accord special weight to the opinions of a claimants physician holding that unlike the social security disability program erisa does not require plan administrators to give special deference to the opinions of treating physicians and noting that there are critical differences between the two programs that nothing in erisa requires employers to establish employee benefit plans and that erisa does not mandate what kind of benefits employers must provide if they choose to have such a plan quotations omitted