Hopper v. Aetna Life Ins. Co.

2015 DNH 191
CourtDistrict Court, D. New Hampshire
DecidedOctober 5, 2015
Docket15-cv-191-LM
StatusPublished

This text of 2015 DNH 191 (Hopper v. Aetna Life Ins. Co.) 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
Hopper v. Aetna Life Ins. Co., 2015 DNH 191 (D.N.H. 2015).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Gary Hopper

v. Civil No. 14-cv-450-LM Opinion No. 2015 DNH 191 Aetna Life Insurance Company

O R D E R

Gary Hopper claims that Aetna Life Insurance Company

(“Aetna”) violated the Employee Retirement Income Security Act

(“ERISA”), 29 U.S.C. §§ 1001-1461, by terminating his long-term

disability benefits under a plan it administered for his

employer. Before the court are motions for judgment on the

administrative record filed by both parties. Each motion is

duly opposed. For the reasons that follow, Aetna’s motion is

granted, and Hopper’s motion is denied.

I. Background

Until May of 2011, Hopper worked as a machinist for Ametek,

Inc. While he was employed by Ametek, he was covered by a plan,

administered and insured by Aetna, that provides both short-term

disability (“STD”) and long-term disability (“LTD”) benefits.

Under that plan, Aetna has “discretionary authority to determine

whether and to what extent eligible employees and beneficiaries are entitled to benefits and to construe any disputed or

doubtful terms under this Policy, the Certificate or any other

document incorporated herein.” Administrative Record

(hereinafter “AR”), at D 000149. The plan further provides that

Aetna “shall be deemed to have properly exercised such authority

unless [it] abuse[s] [its] discretion by acting arbitrarily and

capriciously.” Id.

Shortly before he left Ametek’s employment, Hopper applied

for and was awarded STD benefits. In his application, Hopper

identified various medical conditions that precluded him from

working in dusty or dirty environments. Those conditions

include allergies, eczema, asthma, Bowen’s Disease, amblyopia,

dry eye, decreased visual acuity, s/p penetrating keratoplasty,

herpes simplex keratitis, open angle glaucoma, and keratoconus.

After Hopper’s STD benefits were exhausted, he was awarded LTD

benefits for a 24-month period running from August 23, 2011,

through August 23, 2013. Under the applicable test of

disability, he was entitled to LTD benefits based upon Aetna’s

determinations that he could not perform the duties of his own

occupation as a machinist, and that his earnings fell below a

specified threshold.

2 Under the Aetna plan, when Hopper had collected LTD

benefits for 24 months, he became subject to a stricter test of

disability that entitled him to LTD benefits only if he was

“unable to work at any reasonable occupation solely because of

an illness, injury or disabling pregnancy-related condition.”

AR, at D 000164. The plan defines “reasonable occupation” as

“any gainful activity” for which a plan participant is “or may

reasonably become, fitted by education, training, or experience;

and [w]hich results in, or can be expected to result in, an

income of more than 80% of [the participant’s] adjusted

predisability earnings.” Id. at D 000182. Under the plan,

eligibility for LTD benefits ends when, among other things, a

plan participant “no longer meet[s] the LTD test of disability.”

Id. at D 000165.

In January of 2013, Aetna notified Hopper that as of August

23, 2013, he would become subject to the stricter “any

reasonable occupation” test and that his claim would be reviewed

under that test. In a letter dated August 15, 2013, Aetna

informed Hopper that he was not entitled to LTD benefits under

the “any reasonable occupation” test because he could perform

the occupations of machinist, bench assembler, and tool

programmer. In rendering that decision, Aetna did determine

3 that Hopper was “precluded from . . . performing tasks that

required the ability to see small print or fine detail without

the use of a magnifying device / ability to adjust print font

sizes.” AR, at D 000285.

Hopper appealed Aetna’s decision. He pointed out that

Ametek had discharged him from his position as a machinist

“because his employers determined that his continued employment

would pose a danger to himself and others.” AR, at D 000287.

He also noted medical issues, including vision problems, that

precluded him from working in the three occupations Aetna

identified, and also asserted that Aetna’s findings were

“inconsistent with those of the social security administration.”

AR, at D 000288.

Initially, Aetna agreed with Hopper. In a letter dated

January 10, 2014, Aetna explained:

Based upon our review of all the information submitted and gathered during the claim and appeal, we have overturned our original decision to terminate Mr. Hopper’s benefits; our review has established that the employment options identified do not fit within all of his physical restrictions and limitations. As a result, [Hopper’s] claim has been returned to the claims operation team and will be re-opened by [the] Disability Benefits Manager (DBM) for review and benefit payment, effective August 23, 2013.

Pl.’s Mem. of Law (doc. no. 13) 13.

4 Approximately three weeks later, Hopper received another

letter from Aetna. In it, Aetna informed Hopper that it agreed

with him that “the original occupations [it had] identified

would not be appropriate as [he was] precluded from working in

an environment that would [involve] expos[ure] to dust and dirt

as this [would] trigger a flare up of [his medical] condition.”

AR, at D 000758. Aetna went on to explain that it had Hopper’s

medical documentation reviewed by a dermatologist and an

ophthalmologist, and then determined that he “would have

sustained full duty work capacity in an office environment.”

Id. Then, based upon a review by a vocational rehabilitation

consultant, Aetna determined that Hopper could work as an

assignment clerk. Aetna also explained that it gave little

weight to the fact that Hopper was receiving Social Security

disability benefits, based upon its own Transferrable Skills

Analysis (“TSA”).

Hopper appealed. Again he argued that Aetna’s denial of

benefits was “inconsistent with the federal government’s

determination that [he] is disabled and eligible for Social

Security Disability benefits.” AR, at D 000193. He also

described his visual impairments and explained that they were

the cause of Ametek’s decision to terminate his employment as a

5 machinist. Finally, he noted his long career as a machinist and

argued that he did not have the education, training, or

experience to perform office work such as the occupation of

assignment clerk.

Aetna affirmed its decision to terminate Hopper’s LTD

benefits. Its decision rationale provides, in pertinent part:

A[n] Opthamology [sic] Peer Review of claimant’s medical file was completed 09/08/2014 and the findings with regard to claimant’s functional impairments were that claimant would be precluded from working with machinery as well as performing fine detail work. Claimant would be able to work full-time in a clean office environment, however, his eye impairments would preclude [him] from performing activities requiring a binocular visual acuity better than 20/40, depth perception, and bilateral peripheral vision. Claimant sent in documentation for his appeal on 07/29/2014 which did not provide any new information involving claimant’s eyes.

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