Donna Geiger v. Aetna Life Insurance Company
2017 U.S. App. LEXIS 245
| 7th Cir. | 2017Background
- Donna Geiger, covered by Sprint’s Aetna long-term disability plan, received LTD benefits for ankle avascular necrosis and back issues beginning in 2010; benefits reduced after Social Security award.
- Plan pays for "own occupation" disability for 24 months, then requires inability to work at "any gainful occupation" ( >60% pre-disability earnings) thereafter.
- Aetna reviewed Geiger near the 24-month mark, obtained an exam and peer reviews, performed surveillance showing shopping/driving, and terminated benefits in May 2012; Aetna later reinstated benefits in May 2013 after additional review.
- Aetna reopened review in late 2013, obtained more surveillance, in-house clinical and vocational reviews (finding sedentary jobs consistent with Geiger’s skills), and again terminated benefits in May 2014; Geiger’s appeal was denied after an outside peer review.
- Geiger sued in federal court seeking reinstatement, argued Aetna’s decision was arbitrary and capricious and sought limited discovery to probe alleged conflicts; the district court denied discovery and granted summary judgment to Aetna.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Aetna’s termination and post-appeal denial were arbitrary and capricious | Geiger: Aetna ignored worsening condition, downplayed pain, and relied on inconclusive surveillance and previously discredited evidence | Aetna: Decision based on multiple independent peer reviews, surveillance, in‑house clinical and vocational analyses showing ability to perform sedentary work | Court: Not arbitrary and capricious; decision had rational support in the record |
| Whether district court abused discretion in denying limited discovery into conflict of interest | Geiger: Allegations of biased reviews and insurer-administrator conflict warranted discovery into reviewers and vocational consultant | Aetna: Implemented procedural safeguards (multiple independent reviews, outreach to treating physicians, video shared with providers) that mitigate conflict concerns | Court: No abuse of discretion; plaintiff failed to show exceptional circumstances or prima facie need for discovery |
Key Cases Cited
- Semien v. Life Ins. Co. of N. Am., 436 F.3d 805 (7th Cir. 2006) (standard for limited discovery when challenging ERISA benefit determinations)
- Edwards v. Briggs & Stratton Ret. Plan, 639 F.3d 355 (7th Cir. 2011) (administrator’s decision need only have rational support)
- Holmstrom v. Metro. Life Ins. Co., 615 F.3d 758 (7th Cir. 2010) (plan administrator may revisit prior benefit decisions based on new information)
- Leger v. Tribune Co. Long Term Disability Benefit Plan, 557 F.3d 823 (7th Cir. 2009) (limitations on re‑litigation of previously discredited evidence but not an absolute estoppel)
- Dennison v. MONY Life Ret. Income Sec. Plan for Emps., 710 F.3d 741 (7th Cir. 2013) (post‑Glenn guidance on when discovery is appropriate in ERISA conflict cases)
- Metro. Life Ins. Co. v. Glenn, 554 U.S. 105 (2008) (existence and gravity of conflict of interest is a factor in ERISA benefit review)
- Raybourne v. Cigna Life Ins. Co. of New York, 700 F.3d 1076 (7th Cir. 2012) (conflicts carry less weight when insurer takes active steps to promote accuracy)
- Marrs v. Motorola, Inc., 577 F.3d 783 (7th Cir. 2009) (assessment of gravity of conflict based on circumstances)