Falk v. Life Insurance Co. of North America

2013 DNH 124
CourtDistrict Court, D. New Hampshire
DecidedSeptember 23, 2013
DocketCV-12-178-JL
StatusPublished

This text of 2013 DNH 124 (Falk v. Life Insurance Co. of North America) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Falk v. Life Insurance Co. of North America, 2013 DNH 124 (D.N.H. 2013).

Opinion

Falk v. Life Insurance Co. of North America CV-12-178-JL 9/23/13

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Richard Falk

v. Civil N o . 12-cv-178-JL Opinion N o . 2013 DNH 124 Life Insurance Company of North America/Cigna Group Insurance

OPINION & ORDER

This case arises out of an employee’s claim for long-term

disability insurance benefits due to disc displacement and

discogenic disease in the cervical and lumbar spine, and their

associated symptoms. Plaintiff Richard Falk, formerly a head

line worker for Unitil Service Corporation, sought benefits from

Life Insurance Company of North America/Cigna Group Insurance

(“LINA”), the claims administrator and insurer under Unitil’s

long term disability insurance plan. LINA denied Falk’s claim,

and Falk brought suit under the Employee Retirement Income

Security Act (“ERISA”), 29 U.S.C. §§ 1001 et seq. asking this

court to overturn LINA’s decision and award him benefits under

the plan. See id. § 1132(a)(1)(B) (authorizing civil actions “to

recover benefits due” under an ERISA plan). LINA answered,

defending its decision, and also filed a counterclaim against

Falk alleging that under the terms of the plan, it is entitled to

recover benefits it contends were overpaid to Falk. See id. § 1132(a)(3); Cusson v . Liberty Life Ins. C o . of Boston, 592 F.3d

215, 230 (1st Cir. 2010). This court has subject-matter

jurisdiction under 28 U.S.C. § 1331 (federal question) and 29

U.S.C. § 1132(e)(1) (ERISA).

Both sides have moved for judgment on the administrative

record, see L.R. 9.4(c), and have submitted a joint statement of

material facts, see L.R. 9.4(b). Each side has also submitted a

list of disputed facts. See id. After oral argument and an

exhaustive review of the record, judgment is granted to LINA on

Falk’s claim, as the record does not establish--even under a de

novo standard of review--that Falk was disabled from performing

“any occupation for which he . . . i s , or may reasonably become,

qualified based on education, training or experience,” as

required for him to qualify for long term disability benefits

under Unitil’s plan. Based on the submitted record, judgment is

granted to LINA on the counterclaim as well.

I. Applicable legal standard

The standard of review in an ERISA case differs from that in

an ordinary civil case, where summary judgment is designed to

screen out cases that raise no trialworthy issues. See, e.g.,

Orndorf v . Paul Revere Life Ins. Co., 404 F.3d 5 1 0 , 517 (1st Cir.

2005). “In the ERISA context, summary judgment is merely a

2 vehicle for deciding the case,” in lieu of a trial. Bard v .

Boston Shipping Ass’n, 471 F.3d 229, 235 (1st Cir. 2006). Rather

than consider affidavits and other evidence submitted by the

parties, the court reviews the denial of benefits based “solely

on the administrative record,” and neither party is entitled to

factual inferences in its favor. Id. Thus, “in a very real

sense, the district court sits more as an appellate tribunal than

as a trial court” in deciding whether to uphold the denial.

Leahy v . Raytheon Co., 315 F.3d 1 1 , 18 (1st Cir. 2002).

Courts apply varying degrees of scrutiny in reviewing a

denial or termination of benefits under ERISA. Review is de novo

“unless the benefit plan gives the administrator or fiduciary

discretionary authority to determine eligibility for benefits or

to construe the terms of the plan.” Firestone Tire & Rubber C o .

v . Bruch, 489 U.S. 1 0 1 , 115 (1989). Thus, if the plan gives the

administrator or fiduciary discretionary authority, “the

administrator’s decision must be upheld unless it is arbitrary,

capricious, or an abuse of discretion.” Wright v . R.R. Donnelley

& Sons C o . Grp. Benefits Plan, 402 F.3d 6 7 , 74 (1st Cir. 2005).

The court will assume, without deciding, that the less

deferential de novo standard of review applies in this case

(though the court appreciates the parties’ thoughtful and

3 thorough arguments on which standard the court should apply). 1

1 The court remains more than a little skeptical about LINA’s reliance on a “Group Disability Insurance Certificate,” which it issued to Unitil for delivery to its employees under the plan, as the source of a grant of discretionary authority to i t . The Certificate explains that it “makes up the Summary Plan Description as required by ERISA,” and LINA, in relying on i t , would therefore seem to run headlong into the Supreme Court’s opinion in CIGNA Corp. v . Amara, 131 S . C t . 1866 (2011). In Amara, the Solicitor General (as amicus curiae) argued–- as LINA does here--that “the ‘plan’ includes the disclosures that constitut[e] the summary plan descriptions.” Id. at 1877. The Court observed that this argument was “difficult to square” with both ERISA’s language, which “suggests that the information about the plan provided by those disclosures is not itself part of the plan,” and “the statute’s division of authority between a plan’s sponsor and the plan’s administrator.” Id. As the Court explained, “ERISA carefully distinguishes these roles,” providing that a plan sponsor “creates the basic terms and conditions of the plan” while the plan administrator “manages the plan, follows its terms in doing s o , and provides participants with the summary documents that describe the plan (and modifications) in readily understandable form.” Id. Finding “no reason to believe that the statute intends to mix the responsibilities by giving the administrator the power to set plan terms indirectly by including them in the summary plan descriptions,” the Court rejected the Solicitor General’s argument, concluding “that the summary documents . . . provide communication with beneficiaries about the plan, but that their statements do not themselves constitute the terms of the plan.” Id. at 1877-78. This holding, coupled with the fact that both the policy (which is the primary plan document) and the Certificate itself take pains to make clear that the Certificate is not a part of the contract of insurance, significantly undercuts LINA’s attempt to rely upon the terms of the Certificate as a grant of discretionary authority. See, e.g., Sullivan v . Prudential Ins. C o . of Amer., N o . 2:12-cv-1173, 2013 WL 1281861 (E.D. Cal. Mar. 2 5 , 2013); Durham v . Prudential Ins. C o . of Am., 890 F. Supp. 2d 390, 395-96 (S.D.N.Y. 2012). The court need not resolve this issue, however, in light of its conclusion that Falk has not carried his burden of showing that he is disabled even under a de novo standard.

4 Under the de novo standard, the court must determine, after a

full review of the administrative record, whether the denial of

benefits was correct. See, e.g., Orndorf, 404 F.3d at 518.

Although the de novo standard allows the court to substitute its

judgment for that of the plan administrator, the claimant still

carries the burden of demonstrating that she is disabled within

the terms of the plan. See id. at 519; see also, e.g., Terry v .

Bayer Corp., 145 F.3d 2 8 , 34 (1st Cir. 1998).

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2013 DNH 124, Counsel Stack Legal Research, https://law.counselstack.com/opinion/falk-v-life-insurance-co-of-north-america-nhd-2013.