Halloran v. Unum Life Insurance Company of America

CourtDistrict Court, D. Minnesota
DecidedJuly 3, 2025
Docket0:24-cv-00199
StatusUnknown

This text of Halloran v. Unum Life Insurance Company of America (Halloran v. Unum Life Insurance Company of America) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Halloran v. Unum Life Insurance Company of America, (mnd 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Andrew Halloran, File No. 24-cv-199 (ECT/ECW)

Plaintiff,

v. OPINION AND ORDER

Unum Life Insurance Company of America,

Defendant.

Denise Yegge Tataryn, Nolan Thompson Leighton & Tataryn PLC, Hopkins, MN, for Plaintiff Andrew Halloran.

Jacqueline J. Herring, Hinshaw & Culbertson LLP, Chicago, IL, and Margaret Ann Santos, Hinshaw & Culbertson LLP, Minneapolis, MN, for Defendant Unum Life Insurance Company of America.

In this ERISA lawsuit, Plaintiff Andrew Halloran seeks to recover long-term disability benefits under an employee welfare benefit plan (the “Plan”) sponsored by his former employer, Tennant Company, and insured and administered by Defendant Unum Life Insurance Company of America. Halloran applied for benefits, and Unum approved his claim and began paying benefits in 2020. In 2022, after paying benefits for two years, Unum determined that Halloran was no longer disabled and terminated his benefits. In line with the Plan’s administrative procedures, Halloran appealed the decision to terminate his benefits. Unum affirmed the initial termination decision, prompting this lawsuit. Halloran and Unum have filed competing motions seeking judgment on the administrative record pursuant to Federal Rules of Civil Procedure 39(b) and 52(a)(1). In doing so, the parties have made clear that they wish the Court to exercise its factfinding function and enter judgment based on the administrative record and briefs filed in

connection with the motions. Judgment will be entered for Unum because Halloran has not established by a preponderance of the evidence that he was disabled under the “any gainful occupation” standard in April 2022, and therefore Unum properly terminated his benefits. I1

A

The Plan provides benefits to covered Tennant employees who become disabled, and for the first twenty-four months after an eligibility period is exhausted, the Plan defines disability based on a “regular occupation” definition. The provision reads: You are disabled when Unum determines that: • you are limited from performing the material and substantial duties of your regular occupation due to your sickness or injury; and

• you have a 20% or more loss in your indexed monthly earnings due to the same sickness or injury. AR at 223. The Plan defines each bolded term. “You” refers to the participant. AR at 244. “Regular occupation” means “the occupation you are routinely performing when your

1 This opinion describes the factual findings and legal conclusions required by Federal Rule of Civil Procedure 52(a)(1). The administrative record runs 2,299 pages in length. It was filed in Bates-numbered order at ECF Nos. 30-1 through 30-9. Citations in this opinion will refer to the administrative record by the short form “AR” and to specific pages by their assigned Bates numbers, located in the bottom-right corner of each page. disability begins,” considering “your occupation as it is normally performed in the national economy, instead of how the work tasks are performed for a specific employer or at a

specific location.” AR at 243. The Plan defines “[l]imited” as “what you cannot or are unable to do.” AR at 241. “Material and substantial duties” are those that “are normally required for the performance of your regular occupation” and “cannot be reasonably omitted or modified.” Id. “Injury” is defined as “a bodily injury that is the direct result of an accident and not related to any other cause.” Id. After the first 24 months of payments, the Plan defines “disabled” by reference to

an “any gainful occupation” standard. This provision reads: After 24 months of payments, you are disabled when Unum determines that due to the same sickness or injury, you are unable to perform the duties of any gainful occupation for which you are reasonably fitted by education, training or experience.

AR at 223. “Gainful occupation” means “an occupation that is or can be expected to provide you with an income within 12 months of your return to work, that exceeds . . . 80% of your indexed monthly earnings, if you are working” or “60% of your indexed monthly earnings, if you are not working.” AR at 240. The Plan also provides that after 24 months of payments, payments will stop “when you are able to work in any gainful occupation on a part-time basis but you do not,” or “the date you fail to submit proof of continuing disability.” AR at 231. “Part-time basis means the ability to work and earn between 20% and 80% of your indexed monthly earnings.” AR at 242. B Halloran worked for Tennant as a sheet metal fabricator. In this position, Halloran

operated machinery to cut or shape metal from raw form into usable parts for assembly or aftermarket needs. AR at 76. The position required standing for 90% of a shift, frequently bending, twisting, squatting, and lifting with arms extended, lifting objects weighing up to 45 pounds, and good manual dexterity. AR at 77. Unum later categorized the position as that of “Metal Fabricator” or “Sheet Metal Production Worker” in the national economy, involving “medium work” that required “exerting up to 50 [pounds] occasionally,” with

“frequent reaching[] and handling” and “occasional walking, standing, [and] reaching upward.” AR at 316, 660–61. Halloran had a history of orthopedic problems in his right shoulder, clavicle, and scapula that did not cause him to be disabled. In 2006, when he was 18, Halloran was involved in a serious motor vehicle accident, after which he was airlifted and treated with

an open reduction internal fixation of the right clavicle.2 AR at 1378. In addition, “[t]here

2 “Open reduction and internal fixation . . . is a type of surgery used to stabilize and heal a broken bone.” Clavicle Fracture Open Reduction and Internal Fixation, Johns Hopkins Med., https://www.hopkinsmedicine.org/health/treatment-tests-and-therapies/ clavicle-fracture-open-reduction-and-internal-fixation (last visited July 2, 2025). The procedure may be used to treat a broken clavicle. See id. “During an open reduction, orthopedic surgeons reposition [the] bone pieces surgically back into their proper alignment.” Id. “Internal fixation refers to the method of physically reconnecting the bones. This method uses special screws, plates, wires, or nails to position the bones correctly. This prevents the bones from healing abnormally.” Id. was a laceration which [sic] proximal3 right biceps injury” resulting in a “residual small defect.” Id. After the accident, Halloran had “winging of the right scapula”4 and “a long

thoracic nerve injury” in his right shoulder. See id. Halloran injured his left shoulder in October 2019. Halloran’s left-shoulder injury occurred when he was at home, serving as the primary caregiver for his wheelchair-bound wife. AR at 153, 447. As Halloran was helping his wife transfer from her wheelchair to the bathroom, she slipped, and he caught her with his arms. AR at 151. He “felt a pop” in his left arm and a pulling sensation, and described cramping, bruising, and a deformity over

the upper arm. Id. Halloran was treated for the left-shoulder injury at Allina Health Sports and Orthopaedic Specialists. Halloran was referred for an MRI of his left shoulder to evaluate his rotator cuff tendon. AR at 153. The MRI revealed a “[f]ull thickness retracted rupture of the long head biceps tendon,” “[m]ild tendinosis and mild partial thickness tearing of

the distal supraspinatus tendon with mild infraspinatus tendinosis,” a “[s]mall

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