Megan King v. Reliance Standard Life Insurance Company

CourtDistrict Court, N.D. Indiana
DecidedMarch 31, 2026
Docket1:23-cv-00443
StatusUnknown

This text of Megan King v. Reliance Standard Life Insurance Company (Megan King v. Reliance Standard Life Insurance Company) is published on Counsel Stack Legal Research, covering District Court, N.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Megan King v. Reliance Standard Life Insurance Company, (N.D. Ind. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

MEGAN KING,

Plaintiff,

v. Case No. 1:23-CV-443-GSL

RELIANCE STANDARD LIFE INSURANCE COMPANY,

Defendant.

OPINION AND ORDER This is an ERISA case in which Plaintiff, Megan King (“King”), asserts that her long-term disability benefits were wrongfully terminated by Defendant, Reliance Standard Life Insurance Company (“Reliance”), the insurance company providing benefits to employees of Medtronic, King’s former employer. The parties have filed cross-motions for judgment on King’s claim for plan benefits pursuant to 29 U.S.C. § 1132(a)(1)(B). [DE 38 & 39]. The motions are fully briefed and ripe for ruling.1 I. BACKGROUND2 King worked as a Senior Care Specialist for Medtronic. [DE 39, ¶ 4]. In August 2018, King was diagnosed with acromegaly when doctors discovered a pituitary adenoma growing on her brain. [Id. at ¶ 15]. Shortly thereafter, King underwent a pituitary hypophysectomy. [DE 38 at ¶ 10]. Due to King’s medical condition, she sought disability benefits through Medtronic. [DE 38 at ¶ 4].

1 A hearing on the motions was held on October 22, 2025. [DE 49]. 2 The parties have stipulated, for purposes of these cross-motions for judgment, that there are no disputes as to any material fact. [DE 50, 4:1-21]. The Court also notes that given the lack of factual dispute here, it will pull from both parties’ statements of material facts. A. The Policy Reliance delivered a group long term disability policy (hereinafter referred to as “Policy”) to Medtronic. [DE 38 at ¶ 1]. King, as an employee of Medtronic, was covered under the Policy. [DE 38 at ¶3; DE 39 at ¶6]. The Policy “provides income replacement benefits for Total Disability from Sickness or Injury” to eligible Medtronic employees. [Id. at ¶ 2]. More specifically it explains that Reliance “will pay a Monthly Benefit if an Insured: (1) is Totally Disabled as the result of a Sickness or Injury covered by this Policy; (2) is under the regular care of a Physician; (3) has

completed the Elimination Period; and (4) submits satisfactory proof of Total Disability to us.” [DE 37 at 18; DE 38 at ¶ 52]. The “Monthly Benefit will stop on … the date the Insured fails to furnish the required proof to Total Disability.” [DE 37 at 19; DE 38 at ¶ 32]. The Policy defines “Total Disability” or “Totally Disabled” to mean “that as a result of an Injury or Sickness[] … during the Elimination Period3 and for the first 12 months for which a Monthly Benefit is payable, an Insured cannot perform the material duties of his/her Regular Occupation[, which is] … the occupation the Insured is routinely performing when Total Disability begins[.]” [DE 37, pg. 10; DE 38 at ¶¶ 5, 7]. The Policy goes on to explain that “after a Monthly Benefit has been paid for 12 months, an Insured [is considered Totally Disabled if he or she] cannot perform the material duties of Any

Occupation.” [DE 37, pg. 10; DE 39 at ¶ 1]. “Any Occupation is one “normally performed in the national economy for which an Insured is reasonably suited based upon his/her education, training or experience.” [DE 37 at 9; DE 39 at ¶ 2]. The Policy further “consider[s] the Insured Totally Disabled if due to an Injury or Sickness he or she is capable of only performing the material duties

3 The Elimination Period is “26 consecutive weeks of Total Disability” that “begins on the first day of Total Disability” and “for which no benefit is payable.” [DE 37 at 7, 9; DE 38 at ¶ 6]. on a part-time basis or part of the material duties on a full-time basis.” [DE 37, pg. 10; DE 39 at ¶ 1]. The Policy also provides for “Monthly Benefits for Total Disability caused by or contributed to by mental or nervous disorders.” [DE 38 at ¶ 28]. However, those benefits are “not [] payable beyond an aggregate lifetime maximum duration of twelve (12) months unless the Insured is in a Hospital or Institution at the end of the twelve (12) month period.” [Id. at 28]. Under the Policy, mental or nervous disorders include “depressive disorders” and “anxiety disorders.”

[Id. at ¶ 29]. B. The Claim History King’s last documented day of work for Medtronic was on August 7, 2018. [DE 38 at ¶ 4]. First, she applied and was approved for the maximum period of short-term disability benefits under the Policy. [DE 39 at ¶8]. Her claim then transitioned to one for long-term disability, which Reliance approved on February 15, 2019. [Id. at ¶9; DE 38 at ¶15]. King’s monthly long-term disability benefit payments commenced on February 6, 2019. [DE 38 at ¶ 16]. Reliance conducted periodic reviews of King’s claim. [DE 38 at ¶ 19-21]. Effective February 6, 2020, King’s claim had been paid for 12 months, which, under the Policy, King was no longer considered unable to work in her “Regular Occupation”, but now she was considered

unable to work in “Any Occupation.” [Id. at ¶ 22-23]. On August 17, 2022, Reliance conducted one of its regular reviews of King’s claim. [DE 38 at ¶ 25-26]. It concluded that “[t]here [wa]s no indication of an impairing physical condition[, because] there [wa]s no indication of residual or recurrent pituitary adenoma.” [Id.]. This determination was made using updated records provided by Dr. Jakacki, King’s primary care physician, and Anna Ryan, King’s neurosurgical advanced practice nurse. [Id. at ¶ 25]. As a result, on September 23, 2022, Reliance informed King that as “of August 17, 2022, [it] ha[d] no medical evidence to support [her] inability to perform sedentary occupations due to recurrent or residual pituitary adenoma …” [Id. at ¶ 33]. Therefore, at that point, Reliance did not consider King’s physical condition to be “Totally Disabl[ing]”. [DE 39 at ¶ 10]. In that same letter, however, Reliance explained that “based on the updates from additional healthcare providers, there is evidence of impairment due to major depression and anxiety disorder … [and therefore,] [m]edical documentation supports [King’s] lack of consistent work function due to psychiatric symptoms beginning on August 17, 2022.” [DE 38 at ¶¶ 34, 36]. Since King

was now being awarded benefits only due to her “mental or nervous disorder”, Reliance informed her that her claim “benefits w[ould] [] terminate upon completion of 12 months, or August 17, 2023.” [Id. at ¶ 37]. On July 28, 2023, less than a month before benefits for her mental condition were set to expire, King appealed Reliance’s 2022 decision to terminate her long-term disability benefits for her physical condition. [DE 38 at ¶ 39]. King requested that Reliance “overturn the denial and make a favorable decision on [her] claim for long-term disability benefits due to physical disability.” [Id. at ¶ 40] (emphasis added). In support of her appeal, she provided Reliance with updated medical records, a Vocational Evaluation, and a favorable Social Security disability determination. [Id. at ¶ 41- 43].

Reliance did not issue a decision nor provide a written notice of extension within the 45- day period mandated by the Department of Labor’s ERISA Claims Procedure Regulations. 4 [DE 39 ¶ 13]. Reliance has acknowledged that the appeal was not timely decided. [DE 38 at ¶ 50].

4 Under DOL Regulations, “the plan administrator shall notify the claimant … of the plan’s adverse benefit determination [or the special circumstances warranting an extension] … 45 days after receipt of the claim by the plan.” 29 C.F.R. § 2560.503-1(f)(3). Failure to do so results in the “administrative remedies available under the plan [exhausted].” § 2560.503(1)(2). Therefore, the administrative remedies available to King were deemed exhausted on September 14, 2023. [DE 39 at ¶ 14; DE 26 at pg. 5]. C.

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Megan King v. Reliance Standard Life Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/megan-king-v-reliance-standard-life-insurance-company-innd-2026.