Garrett v. Prudential Insurance Co. of America
107 F. Supp. 3d 1255
M.D. Fla.2015Background
- Plaintiff seeks LTD benefits under ERISA for disability from Health Management Associates; Prudential administers the plan.
- Plan grants Prudential discretionary authority to determine eligibility and interpret terms; SPD references discretionary review.
- Medical evidence includes treating physicians’ disability opinions and multiple non-examining reviews; some reviews found no disabling impairment.
- Prudential terminated LTD benefits after reviews; Plaintiff appealed, triggering independent medical and vocational assessments.
- Court applies de novo review first, then, if discretion exists, applies deferential arbitrary-and-capricious review; also considers potential conflict of interest.
- Court grants Prudential summary judgment and denies Plaintiff’s; final judgment entered for Prudential.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| De novo wrongful denial | Treating physicians’ opinions show disability and work preclusion. | Reviewers found no objective impairment; relied on consistent medical data. | Not de novo wrong; denial reasonable. |
| Discretionary authority in plan | SPD not part of contract; no discretion to Prudential. | HMA plan document grants discretionary authority to Prudential. | Plan grants discretion; Prudential entitled to deference. |
| Standard of review applied | Should apply de novo entirely, not deferential. | Discretion triggers deferential review. | Deferential review applied due to discretionary authority. |
| Conflict of interest weight | Structural conflict should heavily weigh against Prudential. | Conflict is a factor, but not controlling given basis for decision. | Conflict given little weight; decision affirmed. |
Key Cases Cited
- Black & Decker Disability Plan v. Nord, 538 F.3d 822 (11th Cir. 2003) (no special weight to treating physicians; conflict may be weighed as a factor)
- Firestone Tire and Rubber Co. v. Bruch, 489 U.S. 101 (Supreme Court 1989) (establishes discretionary review framework for plan interpretations)
- Kirwan v. Marriott Corp., 10 F.3d 784 (11th Cir. 1994) (discretionary authority under plan supports arbitrary-and-capricious review)
- Blankenship v. Metro. Life Ins. Co., 644 F.3d 1350 (11th Cir. 2011) (six-step ERISA review framework and deferential standard analysis)