Doroshow v. Hartford Life & Accident Insurance Co.

Summary

Jay Doroshow appealed the denial of long-term disability benefits under an ERISA-governed employee welfare benefit plan issued and administered by Hartford Life and Accident Insurance Company. The United States Court of Appeals for the Third Circuit held that Hartford's decision was reasonable under the abuse-of-discretion standard, considering its conflict of interest as one factor under Metropolitan Life Insurance Co. v. Glenn, and affirmed summary judgment for Hartford.

Holdings

1. When an ERISA plan grants the administrator discretionary authority to determine eligibility for benefits, the administrator's decision is reviewed for abuse of discretion under an arbitrary-and-capricious standard; a conflict of interest is considered as one factor among several and does not itself require a heightened standard of review.
2. Hartford reasonably determined that Doroshow received advice pertaining to ALS during the plan's three-month look-back period, so ALS qualified as a preexisting condition and Hartford's denial of long-term disability benefits was not arbitrary and capricious.

Questions Presented

1. What standard of review applies to an ERISA benefits determination when the plan grants the administrator discretionary authority and the administrator both funds and administers the plan?
2. Whether Hartford reasonably determined that Doroshow had received medical advice concerning ALS during the applicable look-back period, making ALS a preexisting condition under the plan.

Disposition

affirmed