New York Judge’s 168 Page Ruling Finds In Favor Of Hartford’s LTD Benefit Denial In ERISA Lawsuit
Author: Attorney Alex Palamara
The ERISA long term disability lawsuit filed against Hartford did not raise any issues out of the ordinary. The Plaintiff sought reversal of the decision to terminate long term disability benefits, unpaid benefits retroactive to the date of the denial, interest on unpaid benefits, attorney’s fees and costs, a declaration that Plaintiff was totally disabled under the Plan’s definition, and future payment of long term disability benefits under the Plan. This case was not handled by our law firm.
Exceptionally Detailed Review Of The Administrative Record
However, in his 168 page Memorandum and Order, the judge scrutinizes every minute fact of the seemingly massive administrative record, and leaves out no detail. The first 90 or so pages of the ruling lay out the extensive detail of the Plaintiff’s personal background and the history of his claim. The judge recounts Hartford’s initial approval of the claim for LTD benefits, the approval of continued benefits once the definition of disability changed to “any occupation”, the details of Plaintiff’s award of Social Security Disability Income benefits, 2 reevaluations and approvals for continued benefits, the termination decision, Hartford’s requests for and reviews of updated medical information, the Peer Reviews and Hartford’s decision to uphold the termination of continued benefits.
Comprehensive Analysis Of Legal Arguments Common In ERISA Actions
The remainder of the Memorandum and Order is devoted to legal analysis of the issues of the lawsuit and the allegations Plaintiff brought against Hartford, all of which are fairly common arguments. If nothing else, the Judge in this case provides us with an extensive amount legal research and comparison of applicable case law which lead him to discredit all of Plaintiff’s arguments and find in favor of Hartford on the issues.
Failure To Provide All Plan Documents
Plaintiff brought an allegation against Hartford involving his request for a copy of the administrative record, claiming that Hartford failed to provide all of the plan documents. This is addressed in detail and the allegation was discredited.
Standard of Review
The judge spent many pages and cited much case law addressing the appropriate standard of review in this matter. The Plaintiff alleged that a de novo standard of review applied in this matter because Hartford purportedly failed to comply with regulatory time requirements when reviewing Plaintiff’s administrative appeal of the benefit denial. The judge ultimately concluded that the deferential standard of review was appropriate in this matter. Thereafter, he analyzes the application of the arbitrary and capricious standard of review.
Denial Not Based On Full And Fair Review Of Medical Evidence
The judge determined that Hartford’s denial of Plaintiff’s claim for LTD benefits was based on substantial evidence after a full and fair review. To reach his determination, he again verbosely discusses Hartford’s initial decision to terminate LTD benefits and Plaintiff’s appeal of the denial, and the discussion is broken down into subparts: Plaintiff alleged that Hartford failed to consider all of the relevant medical evidence; Plaintiff alleges that the SSDI award was not taken into consideration; Plaintiff challenged Hartford’ reliance on the opinions of its Peer Reviewers and argued regarding their lack of expertise and Plaintiff’s lack of opportunity to offer rebuttal, and the judge examined the issue of whether Hartford had an obligation to perform an IME or FCE; and Plaintiff alleged that he was denied a full and fair review due to the fact that Hartford performed video surveillance of him.
Conflict of Interest
Much consideration was also given to Plaintiff’s allegation that a conflict of interest existed. Plaintiff attempted to request the Court to take judicial notice of a certain affidavit, which was filed in a separate matter and was a matter of public record, which dealt with Hartford’s claim handling practices. Plaintiff attempted to offer this affidavit into evidence in rebuttal of certain documents presented by Hartford. However, the Judge found that Plaintiff was not compliant with Federal Rule of Civil Procedure 26 disclosure requirements and that the affidavit was not amenable to judicial notice. After much discussion and comparison of applicable case law on this issue, the Judge determined that the Court would accord no weight to the purported conflict of interest.
Ultimately, the judge concluded that Hartford’s decision to terminate LTD benefits survived scrutiny under either arbitrary and capricious or de novo review. Hartford’s Motion for Summary Judgment was granted, Plaintiff’s cross-motion for judgment was denied and his Complaint was dismissed.
If you have questions regarding your claim for disability benefits with Hartford Insurance Company, or if your disability claim has been denied, feel free to call Disability Attorneys Dell & Schaefer for a free consultation.