Diane Miller v. Hartford Life & Acc. Ins Co., 944 F.3d 1006

Diane Miller, an Integris Health employee, received long-term disability (LTD) benefits from a Hartford group policy beginning November 11, 2012 for mental illness (depression/psychosis); mental-illness benefits were capped at 12 months.
Hartford terminated mental-illness benefits as exhausted effective November 10, 2013; Miller later claimed her psychiatric symptoms were secondary to a physical (thyroid/autoimmune) condition and sought continued LTD for a physical disability.
Hartford reviewed extensive records, obtained independent physical and psychiatric examinations, and had records reviewed by Dr. Taral Sharma (psychiatrist). Reviewers found no disabling physical impairment and no ongoing mental illness requiring work restrictions.
Hartford notified Miller of termination of benefits (October 1, 2016) and denied her internal appeal after additional review addressing medication side effects and psychotic-episode complaints.
Miller sued under ERISA seeking reinstatement; the district court granted judgment for Hartford on the administrative record. The Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard of review / conflict of interest	Miller urged de novo review, alleging procedural failings and inadequate claim development	Hartford argued plan grants discretionary authority; abuse-of-discretion applies (with conflict weight considered)	Abuse-of-discretion applied; no procedural breach warranting de novo review
Sufficiency of evidence that a physical disability existed	Miller: her psychosis was secondary to a thyroid/autoimmune disorder and reviewers ignored physical-cause evidence	Hartford: record lacks treatment/evidence of disabling physical impairment; reviewers reasonably found no physical disability	Substantial evidence supports Hartford’s finding of no disabling physical condition
Reliance on non-treating (reviewing/examining) physicians	Miller: Hartford improperly favored reviewing doctors over her treating psychiatrist	Hartford: permissible to credit reviewing/examining opinions when record supports denial	Court: Administrator may rely on reviewing/examining opinions over treating physician when record supports decision
Full and fair review / procedural adequacy	Miller: Hartford failed to notify her of contact with psychiatrist and neglected medication side effects	Hartford: furnished detailed reasons, extensive record review, and obtained additional analysis on side effects	Court: Hartford afforded a full and fair review; any single unnotified communication did not prejudice Miller

Johnston v. Prudential Ins. Co. of Am., 916 F.3d 712 (8th Cir. 2019) (standard for appellate review of ERISA benefits decisions)
McClelland v. Life Ins. Co. of N. Am., 679 F.3d 755 (8th Cir. 2012) (deferential review when plan grants discretion)
Green v. Union Sec. Ins. Co., 646 F.3d 1042 (8th Cir. 2011) (abuse-of-discretion standard explained)
Nichols v. Unicare Life & Health Ins. Co., 739 F.3d 1176 (8th Cir. 2014) (consideration of administrator-insurer conflict of interest)
Midgett v. Washington Grp. Int’l Long Term Disability Plan, 561 F.3d 887 (8th Cir. 2009) (definition of substantial-evidence review under abuse-of-discretion)
Dillard’s Inc. v. Liberty Life Assurance Co. of Boston, 456 F.3d 894 (8th Cir. 2006) (permissible to credit reviewers over treating physicians when record supports denial)
DuMond v. Centex Corp., 172 F.3d 618 (8th Cir. 1999) (ERISA notice and full-and-fair-review requirement)
Rittenhouse v. United Health Grp. Long Term Disability Ins. Plan, 476 F.3d 626 (8th Cir. 2007) (courts must not substitute their judgment when administrator’s decision is supported by record)
Waldoch v. Medtronic, Inc., 757 F.3d 822 (8th Cir. 2014) (procedural irregularity must be a serious breach to change standard of review)