Maher v. Massachusetts General Hospital Long Term Disability Plan
665 F.3d 289
1st Cir.2011Background
- Maher, a registered nurse, began work at Massachusetts General Hospital (MGH) in 2001 and later received long-term disability benefits; disability attributed to chronic pancreatitis, chronic pain, fibromyalgia, with narcotic pain management.”
- Liberty Life terminated Maher’s benefits in 2007 after a misquoted plan provision was corrected; Liberty relied on surveillance video of Maher engaging in activity and on medical assessments by Liberty doctors deeming her not totally disabled.
- Maher appealed through Liberty and Partners; the district court granted summary judgment for the Plan under a deferential arbitrary-and-capricious standard.
- The majority holds that the Plan delegates discretionary authority to Partners to determine eligibility and administer benefits, and that the district court should have applied a de novo review with respect to the denial, but that remand is appropriate for further explanation and supplementation of the administrative record.
- The dissent argues that there was no clear delegation to Partners and that de novo review should apply, vacating the district court’s judgment if Maher’s disability is established.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there a valid delegation of discretionary authority to Partners? | Maher: no explicit delegation; Hospital retains authority. | Plan language and accompanying documents show delegation to Partners. | Delegation existed; Partners authorized to decide benefits under ERISA. |
| What standard of review applies to Maher’s benefits denial? | De novo review should apply if delegation is lacking; otherwise deferential. | If delegation valid, apply arbitrary-and-capricious standard. | With delegation, deferential review governs; remand for further explanation. |
| Do the record facts support Maher’s disability to perform sedentary nursing work? | Treating physicians’ findings and Maher’s testimony show disability. | Surveillance and independent reviewers show inconsistencies and capacity for sedentary work. | Record supports Maher’s limitations; remand for further, fuller explanation and record supplementation. |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (Supreme Court 1989) (establishes deferential review when discretionary authority is granted)
- Cusson v. Liberty Life Assurance Co. of Boston, 592 F.3d 215 (1st Cir. 2010) (applies arbitrary-and-capricious standard for delegated determinations)
- Rodriguez-Abreu v. Chase Manhattan Bank, N.A., 986 F.2d 580 (1st Cir. 1993) (delegation requires clear evidence of transfer of authority)
- Terry v. Bayer Corp., 145 F.3d 28 (1st Cir. 1998) (requires clear delegation language for express authorization to delegate)
- Wallace v. Johnson & Johnson, 585 F.3d 11 (1st Cir. 2009) (delegation of authority evaluated against plan language; not overly formalistic)