980 F.3d 541
6th Cir.2020Background
- Richard Davis, a U.S. Bank senior application developer, received ERISA-governed long-term disability (LTD) benefits under a Hartford Life policy that vested Hartford Life with discretionary authority to determine benefits.
- Davis suffered from multiple myeloma, back pain, neuropathy, and fatigue; Hartford initially approved LTD benefits but later received conflicting medical opinions about his functional capacity.
- Hartford conducted surveillance, solicited treating-physician input, obtained independent medical examinations, and prepared Employability Analysis Reports identifying transferable sedentary/light occupations meeting the policy’s “Any Occupation” earnings-potential requirement.
- Hartford terminated benefits, concluding Davis could perform full-time sedentary or light work with restrictions; Davis appealed and Hartford obtained further independent reviews that supported termination.
- Davis sued under 29 U.S.C. § 1132(a)(1)(B) (benefits), and § 1132(a)(3) (breach of fiduciary duty and disgorgement); the district court dismissed the equitable claims and granted summary judgment for Hartford on the benefits claim; the Sixth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of review (discretionary authority) | Davis: Decisionmakers were paid by Hartford Fire (a different subsidiary), so Hartford Life didn’t exercise the plan-granted discretion and de novo review applies | Hartford: Decisionmakers adjudicated Hartford Life policies, acted on behalf of Hartford Life, and correspondence/declarations show Hartford Life exercised authority | Court: Hartford Life exercised discretionary authority; arbitrary-and-capricious review applies |
| Termination of benefits arbitrary or capricious? | Davis: Hartford improperly discounted treating physician (Reddy), relied on surveillance and speculation, and failed to show improvement | Hartford: Used multiple treating physicians, independent reviewers, surveillance, and employability analysis; followed a reasoned process supported by evidence | Court: Decision resulted from a deliberate, principled reasoning process and was supported by substantial evidence; not arbitrary or capricious |
| Employability Analysis & median wages/job selection | Davis: Reports misidentified limitations, overstated transferable jobs, and median wages misrepresent actual earnings | Hartford: Reports relied on multiple medical opinions and standard vocational measures; policy focuses on earnings potential so median wages are appropriate | Court: Analysis and wage metric were reasonable and adequately supported |
| Equitable claims under § 1132(a)(3) (fiduciary breach, disgorgement) | Davis: Equitable relief appropriate; district court couldn’t determine adequate remedy at pleading stage | Hartford: Relief available under § 1132(a)(1)(B) (benefits) makes (a)(3) relief unavailable absent a distinct injury | Court: Dismissed (a)(3) claims — injuries were not distinct from denied benefits and (a)(1)(B) provides an adequate remedy |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (standard for ERISA benefits-review; discretionary authority triggers deferential review)
- Clemons v. Norton Healthcare Inc. Ret. Plan, 890 F.3d 254 (6th Cir. 2018) (application of arbitrary-and-capricious standard)
- Shelby Cnty. Health Care Corp. v. Majestic Star Casino, 581 F.3d 355 (6th Cir. 2009) (when decision by entity other than named administrator can trigger de novo review)
- McClain v. Eaton Corp. Disability Plan, 740 F.3d 1059 (6th Cir. 2014) (scope and deference of arbitrary-and-capricious review)
- Rochow v. Life Ins. Co. of N. Am., 780 F.3d 364 (6th Cir. 2015) (narrow availability of § 1132(a)(3) equitable relief; need for a distinct injury)
- Varity Corp. v. Howe, 516 U.S. 489 (interpretation of § 1132(a)(3) as a limited "catchall" equitable remedy)
- Black & Decker Disability Plan v. Nord, 538 U.S. 822 (treating-physician opinions not automatically conclusive in administrator determinations)
- McDonald v. W.-S. Life Ins. Co., 347 F.3d 161 (6th Cir. 2003) (administrator may rationally credit one medical opinion over another)