Cochran v. Trans-General Life Insurance

12 F. App'x 277
CourtCourt of Appeals for the Sixth Circuit
DecidedApril 13, 2001
DocketNos. 99-2102, 99-2447
StatusPublished
Cited by4 cases

This text of 12 F. App'x 277 (Cochran v. Trans-General Life Insurance) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cochran v. Trans-General Life Insurance, 12 F. App'x 277 (6th Cir. 2001).

Opinion

OPINION

NORRIS, Circuit Judge.

Raymond Cochran, as conservator of Regina Hunter (Hunter), brought suit under § 1132(a)(1)(B) of the Employee Retirement Income Security Act of 1974, 29 U.S.C. § 1001 et seq. (ERISA), after the defendant, Trans-General Life Insurance Company (Trans-General), terminated Hunter’s long-term disability benefits. The district court affirmed the decision of the plan administrator to terminate benefits, denied Hunter’s motion for reconsideration and imposed sanctions on Hunter’s counsel under 28 U.S.C. § 1927. Hunter now appeals on the grounds that the district court applied the wrong standard of review to the plan administrator’s decision, erroneously found that Hunter suffered from a mental disability, and abused its discretion by ordering counsel to pay Trans-General’s reasonable attorneys’ fees and costs under 28 U.S.C. § 1927. For the reasons set out below we AFFIRM the decision of the district court in part and REVERSE in part.

I.

Beginning in July 1989, Hunter worked as the director of consultation, education and prevention at the Detroit East Community Mental Health Center (Health Center). As an employee of the Health Center, Hunter became the beneficiary of a long-term disability policy (Plan) purchased by her employer from Group America Insurance Company (later known as Trans-General).1 The Plan was created and operated pursuant to ERISA. The relevant portions of the Plan provided that long-term disability benefits would be paid for 24 months, but that payment beyond this period would be conditioned upon the claimant’s being disabled from all occupations. Further, long-term benefits for a disability caused, or contributed to, by a mental disorder, were only payable for 24 months.

On May 6, 1990, Hunter was involved in a four-car chain reaction collision. As a result of this accident Hunter suffered from a closed head injury, post-concussion syndrome and associated neuropsychological difficulties. Unable to return to her previous job, Hunter received disability benefits from Trans-General from November 7, 1990 to November 7, 1992. In January 1992, Trans-General informed Hunter that her eligibility to receive benefits past November 7,1992, was contingent upon her being disabled from all occupations. Following a report from Hunter’s primary care physician, which indicated that Hunter could perform light work, Trans-General requested an independent medical examination. A neurologist con[280]*280ducted the exam in July 1992, and reported that Hunter’s “neurologic examination was normal” and that there was no need for restrictions or limitations to be placed on Hunter. Following this report, Trans-General informed Hunter that her benefits would be discontinued on November 6, 1992, as she had not shown that she was disabled from all occupations.

On December 10, 1992, Hunter replied to this letter by asking that Trans-General consider further information submitted by another one of her doctors. Trans-General considered the report and, on February 16, 1993, informed Hunter that it would not alter its decision to terminate benefits. After an interval of almost five years, Hunter re-applied for benefits in 1997. Trans-General considered Hunter’s letter an appeal from the denial of benefits in 1992, and rejected it as untimely.

Hunter then brought an action in the Michigan courts, alleging breach of contract and violation of § 1132(a)(1)(B) of ERISA. Following removal to federal court, Trans-General filed a motion for summary judgment; the district court, construing the motion as one for entry of judgment affirming the plan administrator’s decision, granted it on July 30, 1999.2 The district court concluded that the plan administrator’s decision to deny continued benefits had been neither arbitrary nor capricious and, alternatively, that the plan administrator would also have been entitled to terminate Hunter’s benefits because of the Plan’s 24-month limit on benefits for disabilities caused by a mental disorder.

Following this decision, Hunter filed a motion for reconsideration, asserting that the district court had erred when it stated that she claimed to suffer from a mental disability and had improperly failed to consider outside evidence unavailable to the plan administrator. Trans-General filed a responsive motion seeking sanctions against Hunter under 28 U.S.C. § 1927. The district court rejected Hunter’s arguments and imposed sanctions on the grounds that Hunter’s filing of a motion for reconsideration contesting the district court’s alternative finding that Hunter suffered from a mental disability amounted to a vexatious multiplication of the proceedings. Following submissions regarding the costs and fees incurred by Trans-General, the district court ordered Hunter’s counsel to pay Trans-General $538.13 in costs and $3,192.25 in attorneys’ fees.

II.

We review the district court’s judgment de novo. See Wilkins v. Baptist Healthcare Sys., Inc., 150 F.3d 609, 613 (6th Cir.1998). In this case Hunter argues that when an insurance company both funds and administers benefits a structural conflict of interest exists that makes application of the arbitrary and capricious standard of review erroneous.

District courts generally review ERISA challenges to denials of benefits under a de novo standard. See Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 115, 109 S.Ct. 948, 103 L.Ed.2d 80 (1989). However, if the plan grants the plan administrator discretion to determine eligibility for benefits, courts review those determinations under the arbitrary or capricious standard of review. See Bartling v. Fruehauf Corp., 29 F.3d 1062, 1071 (6th Cir.1994). In this case, the parties agree that the plan administrator had discretion to determine Hunter’s continued [281]*281eligibility for benefits; the plan administrator’s decision is therefore reviewed under the arbitrary and capricious standard. “The arbitrary or capricious standard is the least demanding form of judicial review of administrative action. When it is possible to offer a reasoned explanation, based on the evidence, for a particular outcome, that outcome is not arbitrary or capricious.” Davis v. Kentucky Fin. Cos. Ret. Plan, 887 F.2d 689, 693 (6th Cir.1989) (quoting Pokratz v. Jones Dairy Farm, 771 F.2d 206, 209 (7th Cir.1985)).

Contrary to Hunter’s assertion, the existence of a conflict of interest shapes application of, but does not change, the arbitrary and capricious standard of review. This court has noted that:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

White v. Standard Insurance
895 F. Supp. 2d 817 (E.D. Michigan, 2012)
McCandless v. Standard Insurance
765 F. Supp. 2d 943 (E.D. Michigan, 2011)
Thompson v. TRANSAM TRUCKING, INC.
750 F. Supp. 2d 871 (S.D. Ohio, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
12 F. App'x 277, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cochran-v-trans-general-life-insurance-ca6-2001.