Stark v. Reliance Standard Life Insurance Company

142 F.4th 1252
CourtCourt of Appeals for the Tenth Circuit
DecidedJuly 8, 2025
Docket24-6137
StatusPublished

This text of 142 F.4th 1252 (Stark v. Reliance Standard Life Insurance Company) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stark v. Reliance Standard Life Insurance Company, 142 F.4th 1252 (10th Cir. 2025).

Opinion

Appellate Case: 24-6137 Document: 36-1 Date Filed: 07/08/2025 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS July 8, 2025

Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

NANCY STARK, as Legal Guardian and Mother of Jill Finley, an incapacitated person,

Plaintiff - Appellant, No. 24-6137 v.

RELIANCE STANDARD LIFE INSURANCE COMPANY,

Defendant - Appellee. _________________________________

Appeal from the United States District Court for the Western District of Oklahoma (D.C. No. 5:23-CV-00967-PRW) _________________________________

Gerald E. Durbin, II, and Marcus Glen Mullins, Durbin, Larimore & Bialick, Oklahoma City, Oklahoma, for Plaintiff-Appellant.

Joshua Bachrach, Wilson Elser Moskowitz, Edelman & Dicker, Philadelphia, Pennsylvania (Leasa M. Stewart, GableGotwals, Oklahoma City, Oklahoma, with him on the brief), for Defendant-Appellee. _________________________________

Before MATHESON, EBEL, and CARSON, Circuit Judges. _________________________________

CARSON, Circuit Judge. _________________________________

Congress enacted the Employee Retirement Income Security Act (“ERISA”) to

protect employee-benefit-plan participants and their beneficiaries by authorizing civil Appellate Case: 24-6137 Document: 36-1 Date Filed: 07/08/2025 Page: 2

suits for ERISA violations. Here, Defendant Reliance Standard Life Insurance

Company terminated Jill Finley’s long-term-disability-insurance coverage. Although

Defendant later reversed its decision and reinstated Finley’s benefits, Plaintiff Nancy

Stark, Finley’s legal guardian, filed suit against Defendant contending that ERISA

entitles Finley to a surcharge for the financial harm Defendant’s wrongful disability-

benefits termination caused Finley. In her complaint, Plaintiff also alleged that

Defendant breached its fiduciary duty to provide internal records for her appeal and

that under Finley’s insurance policy, it wrongfully deducted the amount she received

from social security payments from her monthly disability payments. The district

court granted Defendant’s Rule 12(b)(6) motion to dismiss for failure to state a claim.

Exercising jurisdiction under 28 U.S.C. § 1291, we affirm.

I.

In May 2007, thirty-one-year-old Jill Finley suffered a sudden death cardiac

arrest resulting in a hypoxic brain injury. At the time, Finley worked as a mortgage

underwriter for Provident Funding Associates, LP, but the injury left her totally

disabled and unable to work. Provident Funding Associates provided long term

disability insurance to its employees through Defendant Reliance Standard Life

Insurance, so in June 2007, Finley filed a claim with Defendant for coverage. Finley

included in her claim a physician’s statement stating that she was “unable to return to

work of any kind at this time” because of her brain injury.

Defendant approved Finley’s claim in January 2008, stating that she

retroactively would receive benefits due from August 2007 to December 2007 and

2 Appellate Case: 24-6137 Document: 36-1 Date Filed: 07/08/2025 Page: 3

that it would need additional information to support disability benefits beyond

December 2007. In the letter approving her claim, Defendant also stated that if she

expected her “illness or injury” to prevent her “from performing substantial work

activity for a period not less than twelve (12) months, it may be in [her] best interest

to apply for Social Security Disability (SSD) benefits.” It continued:

Under certain circumstances, your group policy allows us to deduct an estimate of the amount of the SSD benefit that you may be eligible to receive (see the applicable policy for details). As it is questionable whether or not your particular illness or injury will prevent you from performing substantial work activity for a period of 12 months, we will not reduce your monthly benefit by an estimated SSD benefit amount at this time. However, should further documentation suggest that you[r] illness or injury will prevent you from performing substantial work activity for a period of 12 months, future [long term disability] benefits payable by Reliance Standard Life Insurance Company may be reduced by an estimated SSD benefit amount. Defendant’s internal Claims Department Administrative Procedure Manual states that

“[u]nder the typical [long term disability] policy, no insured is required to file a

claim for Social Security benefits.” But, it continues, “it is often in their best interest

to do so.”

In a February 2008 letter, Defendant informed Finley that it would begin

deducting her estimated SSD from her monthly benefit payments in accordance with

the Benefits Provisions section of her long-term-disability-insurance policy. The

Benefits Provisions describes how Defendant calculates an insured’s monthly

payable amount. It states that Defendant will pay an insured a monthly amount offset

by an insured’s “Other Income Benefits” such as “disability or Retirement Benefits

under the United States Social Security Act” which “an Insured is eligible to receive

3 Appellate Case: 24-6137 Document: 36-1 Date Filed: 07/08/2025 Page: 4

because of his/her Total Disability or eligibility for Retirement Benefits.” It also

states that:

The Monthly Benefit will be reduced by the estimated amount. If benefits have been estimated, the Monthly Benefit will be adjusted when we receive proof: (1) of the amount awarded; or (2) that benefits have been denied and the denial cannot be further appealed. If we have underpaid the Monthly Benefit for any reason, we will make a lump sum payment. If we have overpaid the Monthly Benefit for any reason, the overpayment must be repaid to us. The policy also clarifies that the monthly payment “will stop on the earliest of . . . the

date the Insured ceases to be Totally Disabled . . . or the date the Insured fails to

furnish the required proof of Total Disability.”

The next month, Finley’s guardian asked Defendant to waive the estimated

SSD deduction from her long-term-disability payments because of financial hardship.

The long-term-disability policy itself does not include a waiver provision, but under

Defendant’s Claims Department Administrative Procedure Manual, Defendant can

waive the offset for estimated SSD benefits in certain circumstances, including

financial hardship. Defendant agreed to waive the estimated SSD deduction while

Plaintiff’s SSD application was pending.

In December 2009, an administrative law judge found that Finley had been

totally disabled since May 26, 2007 and was entitled to SSD benefits starting

November 2007. In March 2010, Defendant sent Finley a letter stating that because

she started receiving SSD payments of $1,034.00 per month, it had overpaid her by

4 Appellate Case: 24-6137 Document: 36-1 Date Filed: 07/08/2025 Page: 5

$27,676.73 because its payments under the policy “should have been reduced by

[her] monthly income from [ ] the SS Administration.” The letter explained that once

Finley reimbursed Defendant for overpayment, her monthly long term disability

benefit would be $966.21—the amount she would have received from Defendant

minus the amount she received from SSD.

For the next several years, Defendant kept paying Finley long-term-disability

payments, and Defendant periodically reviewed Finley’s claim to ensure Finley

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142 F.4th 1252, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stark-v-reliance-standard-life-insurance-company-ca10-2025.