Salomaa v. Honda Long Term Disability Plan, 642 F.3d 666

Salomaa worked for Honda for over 20 years and was highly regarded before contracting chronic fatigue syndrome (CFS) after fall 2003 illness.
He applied for Honda’s ERISA long-term disability benefits; the plan denied in 2005 based on lack of objective findings.
Salomaa’s doctors diagnosed CFS with significant cognitive and physical impairment; plan relied on absence of objective test results.
The plan administrator sought to base denial on external medical reviews and limited examination, without providing Salomaa access to certain records.
After administrative denial, Salomaa pursued district court under ERISA; court upheld denial under abuse-of-discretion review with conflict-of-interest considerations.
This case centers on whether the plan abused discretion when denying benefits given a clear conflict of interest and the medical evidence of disability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether conflict of interest affects abuse of discretion standard.	Salomaa argues plan’s dual role requires heightened skepticism and reversal.	Honda contends standard remains deferential under Glenn/Conkright.	Yes; conflict influences the degree of skepticism applied.
Whether denial was reasonable given medical evidence of disability.	All treating physicians found disability; lack of objective tests should not defeat claim.	Absence of objective tests justified denial given reliance on file reviews.	Plan denial was not reasonable; abuse of discretion established.
Whether plan failed to follow proper claims procedure and dialogue.	Plan failed to provide fair opportunity for evidence and timely physician access.	Procedural missteps were not fatal to denial.	Procedural violations contributed to abuse of discretion.
Whether SSA disability award should have influenced the ERISA decision.	SSA award is relevant and should be weighed; failure to address supports arbitrariness.	SSA award not binding and may be given limited weight.	SSA award should have been considered as part of the record; its neglect supports reversal.
Whether the plan’s reliance on objective testing mischaracterized CFS.	Objective neuropsychological evidence supports disability despite timing.	Timing of evidence cannot rectify denial based on absence of objective tests.	Plan’s demand for objective testing was inappropriate and contributed to abuse.

Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (Supreme Court, 1989) (established default abuse of discretion with plan discretion; conflict weighs as factor under Glenn)
Abatie v. Alta Health & Life Ins. Co., 458 F.3d 955 (9th Cir. 2006) (conflict must be weighed as a factor in abuse of discretion analysis)
Metropolitan Life Insurance Co. v. Glenn, 554 U.S. 105 (Supreme Court, 2008) (conflict of interest is a factor to weigh in reviewing benefit denials)
Conkright v. Frommert, 130 S. Ct. 1640 (Supreme Court, 2010) (deferential review remains; one honest mistake does not remove deference)
Saffon v. Wells Fargo & Co. Long Term Disability Plan, 522 F.3d 863 (9th Cir. 2008) (skepticism based on conflict of interest; require meaningful dialogue)
Jordan v. Northrop Grumman Corp. Welfare Benefit Plan, 370 F.3d 869 (9th Cir. 2004) (early formulation of ‘any reasonable basis’ test; conflict considerations later refined)
Montour v. Hartford Life & Accident Ins. Co., 588 F.3d 623 (9th Cir. 2009) (ERISA/SSA distinctions; evaluating disability evidence)
Friedrich v. Intel Corp., 181 F.3d 1105 (9th Cir. 1999) (no single diagnostic test; diagnosis by exclusion in CFS)
Booton v. Lockheed Med. Ben. Plan, 110 F.3d 1461 (9th Cir. 1997) (procedural failures and need for meaningful dialogue)
Saffon v. Wells Fargo & Co. Long Term Disability Plan, 522 F.3d 863 (9th Cir. 2008) (reiterated heightened skepticism when plan is conflicted)