Godmar v. Hewlett Packard Company
2:14-cv-12153
| E.D. Mich. | Mar 30, 2015Background
- Plaintiff Donald Godmar, an HP senior program manager, applied for long-term disability benefits after severe left-leg injuries from a 2009 water‑skiing accident and multiple surgeries (applied June 1, 2012).
- The HP Disability Plan defines “total disability” (after 24 months) as inability to perform any occupation for which one is reasonably qualified; determinations are made on objective medical evidence and the plan grants discretionary authority to the Claims Administrator.
- Sedgwick initially approved benefits for June 1–30, 2012 to avoid a lapse while obtaining records, then terminated benefits as of July 1, 2012 due to lack of objective evidence supporting continued disability.
- Godmar appealed twice and submitted additional records (including treating physicians Drs. Schwarz and Rosenberg). Sedgwick obtained independent file reviews from three physician reviewers (psychiatry, physiatry, neurosurgery), who collectively produced multiple reports and consulted with treating providers.
- Reviewers relied on objective findings (improved EMG vs. 2010, negative x‑ray, treating notes showing normal gait or no work restrictions) and concluded the record did not support “total disability”; Sedgwick conceded a brief benefits period for an inpatient stay for opiate issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether arbitrary and capricious to terminate benefits after initially approving them | Godmar: termination unexplained and unsupported because his condition didn’t improve; initial approval creates inconsistency | Sedgwick: initial approval was temporary to avoid lapse while awaiting records; later decision rationally based on additional objective records | Court: Held not arbitrary; reversal rationally explained and supported by evidence |
| Whether file reviews (no IME) rendered the denial arbitrary | Godmar: reliance on file review improperly discounted subjective pain and treating opinions; IME was needed | Sedgwick: file reviews by qualified physicians plus multiple consultations and comprehensive record review were reasonable | Court: Held file reviews were permissible; procedures were adequate given multiple reviewers and physician-to-physician contacts |
| Whether reviewers improperly rejected treating physicians’ opinions/subjective complaints | Godmar: treating doctors said he was disabled; reviewers made credibility determinations without exam | Sedgwick: reviewers considered treating opinions but found them inconsistent with objective data and consulted treating doctors | Court: Held reviewers reasonably weighed treating opinions against objective evidence; not arbitrary |
| Whether substantial evidence supported denial under the plan’s objective‑evidence requirement | Godmar: chronic pain and surgeries constitute sufficient evidence of disability | Sedgwick: objective tests and treating notes showed improvement/no work restrictions; subjective complaints insufficient alone | Court: Held substantial evidence supported denial; plan’s objective requirement unmet |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (standard of review for ERISA benefit denials)
- Wulf v. Quantum Chemical Corp., 26 F.3d 1368 (6th Cir. discretionary‑authority requirement)
- Wilkins v. Baptist Healthcare Sys., 150 F.3d 609 (administrative‑record de novo review limits)
- Kramer v. Paul Revere Life Ins. Co., 571 F.3d 499 (benefit cancellation without explanation may be arbitrary)
- Morris v. Am. Elec. Power Long‑Term Disability Plan, [citation="399 F. App'x 978"] (administrator must have rational basis for reversal; new evidence not required)
- Calvert v. Firstar Fin., 409 F.3d 286 (file review by qualified physician not inherently improper)
- Helfman v. GE Group Life Assurance Co., 573 F.3d 383 (failure to conduct IME may raise questions when plan reserves right)
- Glenn v. Metropolitan Life Ins. Co., 461 F.3d 660 (treating physician opinions cannot be arbitrarily disregarded)
- Bennett v. Kemper Nat'l Servs., Inc., 514 F.3d 547 (denial must follow deliberate, principled reasoning supported by substantial evidence)