Mark Lloyd v. P&G Disability Benefit Plan
20-4329
| 6th Cir. | Sep 3, 2021Background
- Mark Lloyd worked as an IT manager at P&G and suffered chronic gastrointestinal problems and fibromyalgia; he was diagnosed by a Cleveland Clinic specialist (Dr. Kirby) with chronic intestinal pseudo-obstruction (CIPO) after years of intermittent severe flares.
- P&G’s Disability Committee (plan administrator) had discretionary authority under the Plan; the Plan defined “Partial Disability” in terms of inability to perform regular job duties but ability to do other work, and “Total Disability” as a condition generally considered totally disabling by the medical profession and usually confining the participant to home or hospital.
- Lloyd filed multiple disability claims: short-term/long-term awards in 2014, a denied claim with onset Nov. 3, 2015 (denied after independent review by Dr. Sheth), and a denied claim with onset Jan. 16, 2017 (denied after independent review by Dr. Strahotin).
- Independent reviewing gastroenterologists (Drs. Sheth and Strahotin) concluded Lloyd lacked objective findings of obstruction or sustained functional impairment; Strahotin concluded he was partially impaired but could work with accommodations and improved on domperidone.
- The district court affirmed the denials except it awarded partial disability for Jan. 17–28, 2017; Lloyd appealed. The Sixth Circuit applied deferential arbitrary-and-capricious review and affirmed in all respects.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of Lloyd’s Dec. 2015 claim was arbitrary and capricious | Lloyd: Plan’s “Total Disability” definition requires only that CIPO be generally considered disabling and home confinement — not an individual work-capacity inquiry | P&G: Plan reasonably requires assessment of the claimant’s individual inability to work; independent reviewer (Dr. Sheth) and lack of objective change supported denial | Court: Affirmed — administrator’s interpretation was reasonable and supported by substantial evidence |
| Whether denial of total disability for Jan. 2017 claim was arbitrary and capricious | Lloyd: Treating specialist (Dr. Kirby) diagnosed CIPO and treating physicians supported total disability; Denial ignored treating opinions | P&G: Independent review (Dr. Strahotin) found improvement on medication, intermittent symptoms, and that Lloyd could work with accommodations | Court: Affirmed denial of total disability; substantial evidence supported the Committee’s reliance on reviewers and conclusion that partial work capacity existed |
| Whether relief should include reinstatement of Lloyd’s employee status / ongoing benefits | Lloyd: Reinstatement necessary to preserve ongoing benefit eligibility and/or full employment reinstatement | P&G: Plan permits termination at will; participant rights end at termination; no allegation he was fired for exercising ERISA rights | Court: Affirmed denial of reinstatement; Plan terms and lack of alleged unlawful termination barred equitable relief |
| Procedural / conflict-of-interest complaints and procedural fairness | Lloyd: Claims that administrators failed to identify needed materials, failed to adequately explain disagreement with treating physicians, and conflict of interest influenced denials | P&G: Procedural claims not pleaded below; administrators provided reasons and independent reviews; conflict exists but no evidence it influenced decisions | Court: Did not reach unpleaded procedural claims on appeal; noted conflict but found no significant evidence it affected outcome |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (standard for judicial review of ERISA benefit denials)
- McClain v. Eaton Corp. Disability Plan, 740 F.3d 1059 (6th Cir. 2014) (arbitrary-and-capricious review requires deliberative principled reasoning supported by substantial evidence)
- Davis v. Hartford Life & Accident Ins. Co., 980 F.3d 541 (6th Cir. 2020) (substantial-evidence standard and de novo review of legal conclusions)
- Black & Decker Disability Plan v. Nord, 538 U.S. 822 (treating-physician weight is not automatic; administrator may credit other evidence)
- Metro. Life Ins. Co. v. Glenn, 554 U.S. 105 (conflict of interest as a factor in abuse-of-discretion review)
- Okuno v. Reliance Standard Life Ins. Co., 836 F.3d 600 (6th Cir. 2016) (ERISA does not require the narrowest specialist for file-review decisions)
- McDonald v. W.S. Life Ins. Co., 347 F.3d 161 (6th Cir. 2003) (administrator may rationally rely on one doctor over another)
- Helfman v. GE Grp. Life Assurance Co., 573 F.3d 383 (6th Cir. 2009) (file reviews are permissible though failure to order an exam can raise concerns depending on context)