Hayes v. Cigna Health and Life Insurance Co
6:18-cv-00542
W.D. La.Sep 17, 2019Background:
- Christopher Hayes, a Schlumberger equipment operator, claimed short-term disability (STD) for neck/back/foot problems beginning August 11, 2016 under the Schlumberger Group Welfare Benefits Plan administered by Life Insurance Company of North America (LINA).
- LINA approved and paid STD benefits from August 18, 2016 through November 25, 2016 but then discontinued benefits, concluding Hayes was no longer disabled under the Plan.
- Treating neurosurgeon Dr. Louis Blanda treated Hayes, ordered MRIs and injections, and issued a written work-status form on November 23, 2016 releasing Hayes to return to regular duty effective November 28, 2016; later oral statements (via a nurse) suggested a heavy-lifting restriction but no written functional-capacity evaluation (FCE) or clear restrictive order was in the record.
- Hayes obtained a second opinion from Dr. Muldowny (January 2017), who recommended conservative care and temporary work restriction but did not quantify functional deficits or order an FCE; medical records documented pain and imaging abnormalities but largely normal strength, reflexes, gait, and no objective measures tying deficits to specific job duties.
- LINA repeatedly requested objective documentation quantifying functional limitations and an explanation tying exam findings to the sedentary/physical requirements of Hayes’s equipment-operator job; because the record lacked such documentation beyond November 25, 2016, LINA denied continued STD benefits and denied Hayes’s appeal.
- Magistrate Judge Hanna recommended affirming LINA’s denial and dismissing Hayes’s ERISA claim with prejudice, finding LINA’s interpretation of the Plan and its factual conclusions were reasonable and not an abuse of discretion; Hayes was not awarded fees.
Issues:
| Issue | Hayes's Argument | LINA's Argument | Held |
|---|---|---|---|
| Whether LINA abused its discretion in terminating STD after Nov. 25, 2016 | Lacked objective basis; treating docs show he couldn’t perform job; Dr. Blanda refused to sign job description | Plan grants LINA discretionary authority; record contains written release to full duty and lacks objective functional limitations beyond Nov. 25 | No abuse of discretion; termination affirmed |
| Weight of treating physician evidence | Dr. Blanda’s treatment and later statements show ongoing restrictions | Written notes/work-status forms from Dr. Blanda released Hayes to full duty; oral nurse comments without written documentation insufficient | Court gave controlling weight to Dr. Blanda’s written releases; oral nurse notes do not override signed records |
| Whether gap in treatment (Nov 23–Jan 3) improperly used to deny benefits | Lack of visits not a proper basis for denial | LINA did not rely solely on the gap; relied on absence of objective functional evidence and written releases | Gap was not dispositive; denial rested on absence of documented functional impairment |
| Entitlement to attorneys’ fees | Seeks fees under ERISA | LINA opposes; no success on merits | Fees denied because Hayes did not achieve any success on the merits |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (1989) (establishes standard of review for ERISA benefits denials)
- Black & Decker Disability Plan v. Nord, 538 U.S. 822 (2003) (treating-physician opinions are reliable evidence but need not be accorded special weight)
- Foster v. Principal Life Ins. Co., 920 F.3d 298 (5th Cir. 2019) (administrator may rely on absence of objective evidence to deny disability)
- Anderson v. Cytec Indus., Inc., 619 F.3d 505 (5th Cir. 2010) (limits on introducing evidence outside the administrative record in ERISA review)
- Nichols v. Reliance Standard Life Ins. Co., 924 F.3d 802 (5th Cir. 2019) (burden on claimant to show administrator abused discretion)
- Ellis v. Liberty Life Assur. Co. of Boston, 394 F.3d 262 (5th Cir. 2004) (abuse-of-discretion/ substantial-evidence standard explained)
- Truitt v. Unum Life Ins. Co. of Am., 729 F.3d 497 (5th Cir. 2013) (ERISA plan administrator not required to investigate beyond the record)
- Holland v. Int’l Paper Co. Ret. Plan, 576 F.3d 240 (5th Cir. 2009) (abuse-of-discretion standard and its application to medical determinations)