Joey Harmon v. Unum Life Ins. Co. of Am.

CourtCourt of Appeals for the Sixth Circuit
DecidedMarch 12, 2024
Docket23-5619
StatusUnpublished

This text of Joey Harmon v. Unum Life Ins. Co. of Am. (Joey Harmon v. Unum Life Ins. Co. of Am.) 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
Joey Harmon v. Unum Life Ins. Co. of Am., (6th Cir. 2024).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 24a0115n.06

Case No. 23-5619

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Mar 12, 2024 ) KELLY L. STEPHENS, Clerk JOEY HARMON, ) Plaintiff-Appellant, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE EASTERN UNUM LIFE INSURANCE COMPANY OF ) DISTRICT OF TENNESSEE AMERICA, et al., ) Defendants-Appellees. ) OPINION )

Before: GRIFFIN, THAPAR, and NALBANDIAN, Circuit Judges.

NALBANDIAN, Circuit Judge. Joey Harmon got permanent disability benefits from

Unum Life Insurance Company of America (Unum) after hurting his back lifting a treadmill at

work. After a long recovery and a move to Miami, he was finally cleared for light work, so Unum

terminated his benefits. He brought an ERISA action in federal court, claiming both that the

termination was arbitrary and capricious and that it was tainted by an internal conflict of interest.

The district court disagreed. We AFFIRM.

I.

On January 6, 2012, Joey Harmon injured his back lifting a treadmill while working as a

facilities technician at a 24 Hour Fitness in Memphis, Tennessee. His position at 24 Hour Fitness

generally required him to be able to lift at least 50 pounds, but after getting back surgery in

November 2012, he was seen by Dr. Jonathan Hyde, who imposed a permanent lifting restriction

of 35 pounds. In 2014, Harmon made a claim for worker’s compensation. As part of that process, No. 23-5619, Harmon v. Unum Life Ins. Co. of Am.

Harmon submitted to an independent medical evaluation from Dr. Apurva Dalal, who gave him a

10-pound restriction. And the following year, a treating physician, Dr. Kenneth Jarolem, restricted

him to five pounds. 24 Hour Fitness could not accommodate either a five- or a ten-pound lifting

restriction, so Harmon was approved for long-term disability benefits on June 6, 2014, and started

receiving them retroactively to June 13, 2013, from Unum, which underwrote for 24 Hour Fitness.

After 24 months of payments, Unum would only continue to consider Harmon disabled if

he were unable to perform “any gainful occupation.” And because Harmon was out of work, Unum

defined “gainful occupation” as a job that pays at least 60% of Harmon’s pre-injury earnings. For

Harmon, that gainful wage was $13.54 or $13.68 an hour, depending on the calculation. When

Unum’s vocational consultant reviewed Harmon’s job prospects in the Memphis labor market in

May 2016, she found that the jobs he could perform with his skillset and physical restrictions only

paid up to $12.33 an hour, so Harmon was still eligible for disability benefits.

Shortly after Unum approved his disability claim, Harmon applied for disability benefits

from the Social Security Administration (SSA) in July 2014. SSA denied his claim in 2015, and

Harmon had a hearing for reconsideration in 2016. In February 2017, after the hearing and its own

review of Harmon’s medical history, SSA independently determined that Harmon was not disabled

and, with some exceptions, could, in addition to sedentary work, perform light work as defined in

20 C.F.R. § 404.1567(b), including the work of a cashier, ticket seller, or assembler.

This determination meant that, according to SSA, Harmon was capable of lifting up to 20

pounds, frequently lifting up to 10 pounds, and doing jobs that involve “a good deal of walking or

standing.” See 20 C.F.R. § 404.1567(b). In light of SSA’s conclusion, Unum added cashier, ticket

seller, and assembler to its vocational analysis, finding that even with those additions, there was

still no gainful employment available for Harmon in the Memphis labor market.

2 No. 23-5619, Harmon v. Unum Life Ins. Co. of Am.

That fall, Harmon disclosed on a phone call with Unum that he was living in Miami,

Florida, and repeatedly lifting 10–15 pounds as part of his regular exercise regimen. And in

October 2017, Unum reached out to Harmon’s treating physician, Dr. Harris Mones, requesting

updated medical records and including a form that asked if Harmon could do work that required

him to occasionally walk, stand, and lift up to 20 pounds, while frequently lifting up to 10 pounds.

Dr. Mones returned two responses by fax—seven days apart—with opposite conclusions. So in

November, Unum had its clinical consultant, Nurse Deborah Ainscough, review Harmon’s

medical records to resolve the discrepancy. She agreed with Dr. Mones’s second fax—that Harmon

was capable of the light work described, emphasizing his lack of prescription pain medication, his

activity levels, and Dr. Hyde’s 35-pound lifting restriction.

In the meantime, Unum conducted a new vocational assessment, focusing on the Miami

labor market and including the light work it and SSA determined Harmon could handle, finding

alternative occupations that paid up to $15.27 an hour—a gainful wage. As a result, Unum

determined that Harmon was no longer eligible for disability benefits. Harmon appealed the

following May. Although Dr. Mones clarified in January 2018 that he did not believe Harmon

could do light work, Unum upheld its termination after its in-house physician, Dr. Beth Schnars,

reviewed Harmon’s medical records.

Harmon then brought an ERISA action in federal court, with the primary claim that Unum’s

decision was arbitrary and capricious. He also argued that the termination of his benefits was

tainted by a conflict of interest, producing weekly tracking reports to claim that Unum’s director

supervising Harmon’s claim, Director Wesley Ridlon, was unduly motivated by financial targets.

The district court disagreed on both, granting Unum’s motion for judgment on the record. Harmon

timely appealed.

3 No. 23-5619, Harmon v. Unum Life Ins. Co. of Am.

II.

We review the district court’s judgment on the administrative record de novo. Bennett v.

Kemper Nat’l Servs., Inc., 514 F.3d 547, 552 (6th Cir. 2008). And because Unum’s policies vest

discretion to determine benefit eligibility, we review the administrator’s decision under the

arbitrary-and-capricious standard. Id. So we uphold that decision when “it is the result of a

deliberate, principled reasoning process” and “supported by substantial evidence,” id., focusing on

the “ultimate decision” rather than “discrete acts,” McClain v. Eaton Corp. Disability Plan, 740

F.3d 1059, 1066 (6th Cir. 2014).

This means that even if the record could “support a finding of disability,” we will affirm

the administrator’s decision “if there is a reasonable explanation” for it. Schwalm v. Guardian Life

Ins., 626 F.3d 299, 308 (6th Cir. 2010).

Harmon challenges Unum’s decision to terminate his benefits as arbitrary and capricious,

citing three main factors: (1) Unum’s reliance on its in-house file-reviewing physician, Dr.

Schnars; (2) Unum’s interpretation of Dr. Mones’s opinions; and (3) Unum’s vocational analysis.

First, Harmon claims Unum’s use of an in-house file reviewing physician over his treating

providers was unreasonable. But “[r]eliance on [non-treating] physicians is reasonable so long as

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