Olayinka Oye v. Hartford Life and Accident Insurance Company

140 F.4th 833
CourtCourt of Appeals for the Seventh Circuit
DecidedJune 12, 2025
Docket24-2925
StatusPublished
Cited by1 cases

This text of 140 F.4th 833 (Olayinka Oye v. Hartford Life and Accident Insurance Company) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Olayinka Oye v. Hartford Life and Accident Insurance Company, 140 F.4th 833 (7th Cir. 2025).

Opinion

In the

United States Court of Appeals For the Seventh Circuit ____________________ No. 24-2925 OLAYINKA OYE, Plaintiff-Appellant, v.

HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY, Defendant-Appellee. ____________________

Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 1:21-cv-03749 — Edmond E. Chang, Judge. ____________________

ARGUED MAY 29, 2025 — DECIDED JUNE 12, 2025 ____________________

Before EASTERBROOK, BRENNAN, and SCUDDER, Circuit Judges. SCUDDER, Circuit Judge. Asserting that her fibromyalgia prevented her from working, Olayinka Oye applied for bene- fits through her employer’s long-term disability plan, admin- istered by Hartford Life and Accident Insurance Company. Hartford determined Oye was disabled, but later reevaluated her condition, found her fit to work, and terminated benefit payments. Oye reacted by filing this suit, seeking a federal 2 No. 24-2925

district court’s review of her benefits claim. In a detailed and diligent opinion, the district court found that Oye’s fibrom- yalgia, while limiting, did not render her disabled under Hartford’s plan. We agree and affirm. I A Olayinka Oye began working at PricewaterhouseCoopers in 2005, earning many promotions and in time becoming a di- rector. Her health took a turn in 2013, however. Suffering from depression, anxiety, and post-traumatic stress disorder, she took a leave of absence to seek treatment. And while Oye briefly returned to work in 2016, she applied for disability benefits through PwC’s Long Term Disability Plan a year later, claiming that she suffered from fibromyalgia, a chronic pain condition, which altogether prevented her from work- ing. As the Plan’s insurer and administrator, Hartford initially denied Oye’s claim. But after Oye appealed the denial, Hart- ford reversed course, found her disabled within the meaning of the Plan, and awarded benefits through 2036. Not long after Oye began receiving benefits, Hartford changed course again. For reasons unclear from the record, the insurer reevaluated Oye’s condition and disability claim in 2020. Relying on the reports of several consultative doctors who reviewed Oye’s medical records, Hartford terminated her benefits, finding her no longer disabled. When Hartford upheld its denial on appeal, Oye turned to the courts. Invoking the Employee Retirement Income Secu- rity Act, Oye filed suit in federal court in Chicago, seeking to No. 24-2925 3

reinstate her long-term disability benefits under the Plan. See 29 U.S.C. § 1132(a)(1)(B) (ERISA’s private right of action). B The parties agreed to a “paper trial” pursuant to Federal Rule of Civil Procedure 52(a), which allows the district court to resolve the dispute without a formal trial by making find- ings of fact and conclusions of law based on the administra- tive record. See Fontaine v. Metro. Life Ins. Co., 800 F.3d 883, 885 (7th Cir. 2015) (observing that Rule 52(a) “is well-suited to ERISA cases in which the court reviews a closed record”). After outlining the history of Oye’s claim and cataloguing the evidence for and against a finding of disability, the district court found that Oye had failed to meet her burden of show- ing that she was disabled within the meaning of the Plan. While observing that Oye’s fibromyalgia no doubt caused pain and limited her abilities, the district court determined that the record evidence, when assessed in its totality, did not support a finding that her condition was so disabling as to render her unable to continue her work at PwC. Most persua- sive, the district court reasoned, was that three of Hartford’s medical reviewers concluded in detailed consultative reports that Oye’s medical records and physical exams did not sup- port her claim of complete disability. These reports, the court explained, belied the brief and conclusory letters from Oye’s treating physicians, which described Oye’s condition as to- tally disabling. The district court also granted judgment in Hartford’s fa- vor on another, independent ground. Under the Plan, Oye only qualified for additional disability benefits if she demon- strated that her disability arose from solely physical, rather 4 No. 24-2925

than mental, conditions. Because the record suggested that Oye’s mental health contributed significantly to her limita- tions, the district court concluded that she failed to establish entitlement to additional benefits under the Plan. Oye now appeals. II A Because the plan did not give Hartford discretion over el- igibility determinations, ERISA obligated the district court to review the administrative record and “come to an independ- ent decision on both the legal and factual issues that form the basis of the claim.” Diaz v. Prudential Ins. Co. of Am., 499 F.3d 640, 643 (7th Cir. 2007); see Firestone Tire & Rubber Co., 489 U.S. 101, 115 (1989) (explaining that “a denial of benefits chal- lenged under § 1132(a)(1)(B) is to be reviewed under a de novo standard unless the benefit plan gives the administrator or fi- duciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan”). Put differently, unlike disability proceedings in the Social Security context and unless the plan provides otherwise, a district court con- sidering ERISA-based disability claims owes no deference to the plan administrator’s decision. See Diaz, 499 F.3d at 643. Oye recognizes this standard in her brief on appeal. But in many places she suggests the district court owed deference to Hartford’s prior determination that she was disabled. Indeed, Oye labors to undermine the district court’s conclusion by pointing out deficiencies in Hartford’s handling of her claim. For example, she faults the district court for disregarding her claim history, insisting that the court should have given weight to the fact that Hartford had previously approved her No. 24-2925 5

claim based on the reports of her treating physicians—the same physicians the district court found unpersuasive. The district court approached its review exactly the right way, owing no deference to Hartford’s prior decisions. See Dorris v. Unum Life Ins. Co. of Am., 949 F.3d 297, 304 (7th Cir. 2020) (describing an ERISA plan administrator’s prior deci- sions as “irrelevant” once a covered employee seeks federal court review). In short, the district court committed no error by affording no weight to Hartford’s prior finding that Oye was disabled. The prior administrative finding had no preclu- sive effect on the district court’s own independent review of the record. B That brings us to the merits of the district court’s decision, with our review being only for clear error. See Hess v. Hartford Life & Acc. Ins. Co., 274 F.3d 456, 461 (7th Cir. 2001). Unless the district court’s factual findings leave us “with the definite and firm conviction that a mistake has been made,” we must af- firm. Marantz v. Permanente Med. Grp., Inc. Long Term Disability Plan, 687 F.3d 320, 336–37 (7th Cir. 2012).

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