Herron v. Hartford Life & Accident Insurance

Summary

The Ninth Circuit affirmed a district court judgment upholding Hartford Life’s discontinuation of Darlene Herron’s long-term disability benefits under an ERISA plan. The court held that the administrator did not abuse its discretion, that the administrative record supported a finding of no disability, and that the district court properly excluded evidence outside that record.

Holdings

1. Hartford Life did not abuse its discretion in denying Herron's claim for continued long-term disability benefits because the administrative record contained adequate evidence supporting a finding of no disability.
2. The district court properly declined to consider evidence offered by Herron that was not contained in the administrative record.

Questions Presented

1. Whether Hartford Life abused its discretion by denying Herron's claim for continued long-term disability benefits.
2. Whether the district court properly limited its review to the administrative record.
3. What standards of review governed the administrator's benefits decision and the underlying factual findings.

Disposition

affirmed