Summary
The United States District Court for the District of Massachusetts considers cross-motions for summary judgment in an ERISA action concerning the denial and termination of Alison Butter’s long-term disability benefits. The court gives little weight to Hartford’s structural conflict of interest but concludes that Hartford may have improperly relied on limited surveillance footage and medical reviews while failing to adequately address contrary medical evidence. Both parties’ motions for summary judgment are denied.
Topics
Practice areas
Questions Presented
- Whether Hartford's structural conflict of interest should substantially affect the deferential review of its benefit determination.
- Whether Hartford's termination and subsequent denial of Butter's long-term disability benefits was arbitrary and capricious because Hartford gave undue weight to limited surveillance evidence and failed to meaningfully address contrary medical evidence.
- Whether either party was entitled to summary judgment.
- Whether remand to the plan administrator was appropriate when the administrator failed to provide the review required under ERISA.
Holdings
- Hartford's structural conflict of interest was entitled to little weight because Hartford used third-party vendors and independent physicians, a separate appeal specialist, and the record did not show a history of biased claims administration or other specified procedural misconduct.
- Hartford's denial and termination decision was inadequately reasoned and unsupported by substantial evidence because it gave undue weight to brief surveillance footage and a single examination, failed to explain why contrary treating-physician opinions were rejected, and did not meaningfully address substantial medical evidence supporting disability.
- Neither Hartford nor Butter was entitled to summary judgment.
- When a plan administrator fails to provide the review required under ERISA, remand to the administrator for further review is appropriate.
Key quotations
“While the “mere existence of contrary evidence in the record is not sufficient to render a determination arbitrary and capricious,” “a plan administrator may not simply ignore contrary evidence, or engage with only that evidence that supports his conclusion,” as here.” (III.B.1)
“While I am inclined to rule in Ms. Butter’s favor, “it would be unwise to take this step without first giving [Hartford] the chance to address the deficiencies in its approach. The record demonstrates that [Ms. Butter] did not get the kind of review to which she was entitled under applicable law.”” (III.C)
“The case is remanded to the plan administrator for further review in accordance with this decision.” (IV)
Factual background
Butter worked for Metrowest Jewish Day School and stopped working in March 2021 because of chronic pain and related physical conditions, including cervical and lumbar pain, fibromyalgia, leg pain, and other impairments. Hartford initially approved long-term disability benefits but terminated them in March 2023 after surveillance, an independent medical examination, and a determination that Butter could perform her own or another occupation. After Butter appealed with additional medical opinions, a functional capacity evaluation, and evidence of an SSDI award, Hartford upheld the termination while relying substantially on its reviewers' assessments and the surveillance evidence.
Procedural history
Butter sued Hartford Life and Accident Insurance Company and the Metrowest Jewish Day School Disability Plan under ERISA after Hartford terminated her long-term disability benefits under the policy's any-occupation standard. Both parties moved for summary judgment. The court denied both motions and remanded the matter to the plan administrator for further review.
Remand instructions
The case is remanded to the plan administrator for further review in accordance with the decision, including meaningful consideration of the contrary medical evidence, the limited surveillance footage, Butter's submitted medical and functional-capacity evidence, and the SSDI award.