478 F. App'x 695
2d Cir.2012Background
- Amanda Martin appeals a district court decision denying summary judgment on her ERISA claim for accidental death benefits and granting Hartford's summary judgment.
- The decedent husband died reportedly after applying household current via a homemade device; Hartford denied benefits under an exclusion for intentionally self-inflicted injury.
- The plan grants Hartford full discretion to determine eligibility and interpret plan terms, triggering deferential review with a potential conflict-of-interest factor.
- The district court found Hartford did not abuse its discretion and relied on the decedent’s intentional self-inflicted activity as the basis for denial.
- Martin challenged the district court’s reliance on Hartford’s interpretation and argued the denial notice and review were not adequately fair.
- This Court vacates and remands for reconsideration consistent with the opinion to address the plan’s interpretation and procedural review issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Hartford abuse discretion on the exclusion? | Martin contends exclusion precludes only intentional acts, not negligent ones. | Hartford maintains its interpretation is permissible under the policy language. | Remanded for reconsideration; not decided. |
| Was there a due process/procedural flaw in the review? | Martin asserts inadequate notice of new rationale and incomplete review. | Hartford argues the review was proper and any new rationale is acceptable. | Remanded for further administrative proceedings consistent with due process. |
Key Cases Cited
- Durakovic v. Bldg. Serv. 32 BJ Pension Fund, 609 F.3d 133 (2d Cir. 2010) (de novo review with consideration of conflict of interest in ERISA decisions)
- Metropolitan Life Ins. Co. v. Glenn, 554 U.S. 105 (S. Ct. 2008) (conflict of interest as a factor in abuse-of-discretion review)
- Krauss v. Oxford Health Plans, Inc., 517 F.3d 614 (2d Cir. 2008) (remand when considering additional evidence during review)
- Miller v. United Welfare Fund, 72 F.3d 1066 (2d Cir. 1995) (remand when necessary for full and fair review)
- Critchlow v. First UNUM Life Insurance Co., 378 F.3d 246 (2d Cir. 2004) (ERISA plan interpretation and deferential review framework)