Scott Griffin v. Hartford Life & Accident Ins.
898 F.3d 371
4th Cir.2018Background
- Griffin, a MedQuist employee, received long-term disability (LTD) benefits from a Hartford Life policy after wrist/forearm/neck/shoulder pain and surgery; benefits initially paid beginning May 2012.
- The policy defined disability as inability to perform Own Occupation for 24 months, then Any Occupation; policy required claimant to provide continuing proof and gave Hartford Life discretionary authority to determine eligibility.
- Post-surgery providers declined to provide current functional assessments; Hartford Life obtained a peer-review report that could not recommend restrictions based on the records and noted the doctors’ reluctance to specify limitations.
- Hartford Life’s special investigations unit conducted surveillance and an in-person interview showing Griffin ambulating and performing tasks without obvious limitation; updated provider responses did not impose current restrictions.
- Hartford Life performed an employability analysis identifying sedentary jobs Griffin could perform and terminated LTD benefits in September 2014; Hartford Life denied his administrative appeal.
- Griffin sued under ERISA §1132(a)(1)(B); district court granted summary judgment to Hartford Life. On appeal, Griffin challenged the standard of review and the reasonableness of the termination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of review: whether abuse-of-discretion or de novo applies | Griffin: decision was made by Hartford Fire (not Hartford Life), which lacked discretionary authority in the policy, so de novo review required | Hartford Life: decisionmakers acted as Hartford Life agents; policy expressly conferred discretionary authority on Hartford Life so deferential review applies | Abuse-of-discretion review applies; decisionmakers were agents of Hartford Life despite payroll records showing Hartford Fire paid salaries |
| Adequacy of evidence supporting termination | Griffin: Hartford Life’s employability analysis ignored medical records and lacked objective support | Hartford Life: medical records contained no current functional restrictions; surveillance, interview, and peer review supported termination | Termination was supported by substantial evidence and was reasonable under abuse-of-discretion standard |
| Burden of proof to terminate previously awarded benefits | Griffin: once benefits granted, Hartford Life must show improvement to terminate | Hartford Life: policy places ongoing burden on claimant to furnish proof of disability; not required to prove improvement | Policy places burden on claimant; Hartford Life need not affirmatively prove improvement and reasonably relied on available evidence |
| Need for independent medical examination (IME) | Griffin: Hartford Life should have required a current physical exam before termination | Hartford Life: policy permits but does not require IME; it reasonably declined given cost and available evidence | Not unreasonable to deny without IME here; administrator need not procure specific evidence when substantial contrary evidence exists |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (standard for de novo vs. discretionary review)
- Haley v. Paul Revere Life Ins. Co., 77 F.3d 84 (administrator’s breach analyzed under contract/trust principles; abuse-of-discretion framework)
- Booth v. Wal-Mart Stores, Inc. Assocs. Health & Welfare Plan, 201 F.3d 335 (factors for assessing reasonableness under abuse of discretion)
- Williams v. Metro. Life Ins. Co., 609 F.3d 622 (decision must result from deliberate, principled reasoning and be supported by substantial evidence)
- Guthrie v. Nat’l Rural Elec. Coop. Assoc. Long Term Disability Plan, 509 F.3d 644 (same standard for review)
- Sheppard & Enoch Pratt Hosp., Inc. v. Travelers Ins. Co., 32 F.3d 120 (review based on facts known to administrator at decision time)
- Elliott v. Sara Lee Corp., 190 F.3d 601 (administrator not required to secure specific forms of evidence)
- Berry v. Ciba-Geigy Corp., 761 F.2d 1003 (administrator not incumbent to secure evidence when reliable counter-evidence exists)
- Metro. Life Ins. Co. v. Glenn, 554 U.S. 105 (structural conflict of interest acknowledged but requires evidence of impact to affect reasonableness)