Ryan v. The Procter & Gamble Company

CourtDistrict Court, S.D. Ohio
DecidedJune 26, 2023
Docket1:20-cv-00556
StatusUnknown

This text of Ryan v. The Procter & Gamble Company (Ryan v. The Procter & Gamble Company) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ryan v. The Procter & Gamble Company, (S.D. Ohio 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

ROBERT RYAN,

Plaintiff, Case No. 1:20-cv-556 v. JUDGE DOUGLAS R. COLE

THE PROCTER & GAMBLE U.S. BUSINESS SERVICES COMPANY,

Defendant. OPINION AND ORDER In recent years, Robert Ryan had wrist and knee injuries—and resulting surgeries. His employer-sponsored health plan from Procter & Gamble offered him only limited partial disability benefits, so he administratively appealed—and eventually sued—seeking more. In Ryan’s view, he is Totally Disabled under the benefit plan’s definition of that term. Unfortunately for him, several doctors and the plan’s administrator disagree. In this suit, he asks the Court to reject the doctors’ view and find him Totally Disabled. Both parties now move for Judgment on the Administrative Record. (See Docs. 16, 17). For the reasons discussed below, the Court GRANTS the Defendant’s Motion (Doc. 16) and DENIES Ryan’s Motion (Doc. 17). BACKGROUND Ryan used to work for Procter & Gamble. (Doc. 6, #17). There, he participated in The Procter & Gamble Health & Long-Term Disability Plan (“Plan”). (Id.). The Plan provides several benefits to company employees, including short and long-term disability benefits, total disability benefits, and partial disability benefits. (See generally Doc. 14-1). As one might imagine, many relevant terms in the Plan have complex

definitions. Relevant today, “Total Disability” is a mental or physical condition resulting from an illness or injury that is generally considered totally disabling by the medical profession and for which the participant is receiving regular recognized treatment by a qualified medical professional. Usually, total disability involves a condition of such severity as to require care in a hospital or restriction to the immediate confines of the home. (Id. at #164). And perhaps not surprisingly, “Totally Disabled” means “a person who has a Total Disability.” (Id.). The Plan explicitly requires the claimant to establish that they are disabled. (Id.). That obligation is continuous, with physician certifications normally needed each month. (Id.). Procter & Gamble itself does not run the Plan. That responsibility instead falls to the plan administrator. (Id. at #154). Here, that administrator is The Procter & Gamble U.S. Business Services Company, the Defendant (“P&G”). (Id.). The plan administrator has all “the power, responsibility, and discretionary authority necessary to carry out the administration” of the Plan. (Id. at #114). All this matters because, in late 2015, Ryan fell while working in his yard and injured his left wrist. (Id. at #285). The fall left him in significant pain and reduced his range of motion to the point that, a few weeks later, he still complained of pain that made it hard for him to move multiple fingers. (Id. at #283). He began receiving disability benefits in early November. (Doc. 6, #18). That next March, he had wrist fusion surgery. (Doc. 14-1, #345). Then, in June, Dr. Nathan Schroeder cleared him to work full-time performing work in the “Sedentary Physical Demand Category.” (Id. at #239). In the following months, Dr. Samir Mahesh Patel noted improvement in Ryan’s wrist multiple times. By October 2016, Patel cleared Ryan to lift up to fifteen

pounds and work eight hours per day but noted that Ryan still had some pain a couple of months later. (Id. at #268–72). In March 2017, Ryan had a second surgery, this time to remove hardware from the previous surgery. (Id. at #476). In September, Ryan saw Dr. Peter J. Stern. Ryan still complained of some pain then, so Dr. Stern assigned him a twenty-five-pound lifting restriction. (Id. at #303–04). Dr. Stern also noted that Ryan had “not been told that he may not be able to return to work.” (Id. at #304).

Against that backdrop, Ryan applied for Total Disability benefits. On September 26, 2017, the Lima Review Board, a local board with authority to review and decide both initial and continuing claims under the Plan, notified Ryan that it had determined him to be Partially Disabled rather than Totally Disabled. (Id. at #433). The Lima Review Board noted that Ryan’s “treating physician indicated that [he] could return to work” with some restrictions. (Id. at #434). Based on that

determination, Ryan began receiving Partial Disability benefits for the fifty-two-week period the Plan specified. That meant his benefits would last him until September 18, 2018. (Id. at #430). Ryan appealed this decision; more on that later. In mid-to-late 2018, Ryan also started having knee pain and sought treatment. (Id. at #214). On August 8, 2018, Dr. Salim Hanna noted that Ryan’s wrist “has been his biggest problem” but that he now had knee pain from “catching clicking and grinding.” (Id.). Ryan could not identify any event that could have caused his newfound knee issues. (Id. at #207). At the end of October, Ryan had surgery to fix his knee trouble. (Id. at #200). After that, Dr. Joseph R. Misson remarked that the

goal would be to “get [Ryan] back to work with some sort of light duty.” (Id. at #198). Dr. Misson approved him for light duty with restrictions in late November. (Id. at #196). On December 14, 2018, Ryan appealed the Lima Review Board’s decision to award him only partially disabled status. (Id. at #315). As part of that appeal, Dr. Elliot Ames reviewed all available records. Dr. Ames concluded that “the objective

medical information does not support” Total Disability and that Ryan could return to work “in any capacity” with the listed restrictions. (Id. at #555). He did not, however, examine Ryan at any time. Based on Dr. Ames’s conclusions, the Disability Committee denied Ryan’s appeal. (Id. at #563). After losing his appeal, Ryan sued in this Court. Both parties believe they are entitled to judgment on the administrative record and have moved accordingly. (See

Docs. 16, 17). LAW AND ANALYSIS As noted, the plan administrator denied Ryan’s appeal. When, as here, a plan administrator had the authority to initially determine a claimant’s eligibility for benefits, the Court reviews that decision in an appellate posture, “only to determine if [the determination] was arbitrary and capricious.”1 Marks v. Newcourt Credit Grp., Inc., 342 F.3d 444, 456–57 (6th Cir. 2003) (cleaned up). This standard is “extremely deferential.” McClain v. Eaton Corp. Disability

Plan, 740 F.3d 1059, 1064 (6th Cir. 2014). And it is “the least demanding form of judicial review.” Lloyd v. Procter & Gamble Disability Benefit Plan, Plan #501, No. 20-4329, 2021 WL 4026683, at *6 (6th Cir. Sept. 3, 2021) (citation omitted). Indeed, the Court will overturn the plan administrator only if the decision was “not just clearly incorrect but downright unreasonable.” Kenny v. Gen. Motors Corp., 24 F. App’x 330, 332 (6th Cir. 2001) (citation omitted). Ryan contends that P&G’s decision was arbitrary and capricious largely

because the administrator did not adequately assess his subjective complaints. He also believes that he is totally disabled. P&G, for its part, stands by the decision (and the resulting appellate process), believing there to be ample evidence that Ryan is not totally disabled. P&G also believes that Ryan has not offered evidence showing his total disability. P&G has the better argument here. The relevant decision was not arbitrary

and capricious. And nothing Ryan put into the record amounts to evidence that the decision was “downright unreasonable.” To start, the evidence reflects that no doctor has declared Ryan Totally Disabled since he was declared only Partially Disabled. Not even his own treating

1 Both the Plan itself and published Sixth Circuit case law confirm this. (See Doc.

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Related

Lloyd Marks v. Newcourt Credit Group, Inc.
342 F.3d 444 (Sixth Circuit, 2003)
Karen McClain v. Eaton Corp. Disability Plan
740 F.3d 1059 (Sixth Circuit, 2014)
Kenny v. General Motors Corp.
24 F. App'x 330 (Sixth Circuit, 2001)
Tanner v. Nationwide Mutual Insurance
804 F. Supp. 2d 601 (S.D. Ohio, 2011)

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Bluebook (online)
Ryan v. The Procter & Gamble Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ryan-v-the-procter-gamble-company-ohsd-2023.