Court Allows Hartford to Pursue Summary Judgment on Exhaustion Grounds in Long-Term Disability Case

In Lucas v. Hartford Life and Accident Insurance Company, No. 24-CV-7561 (VEC), 2025 WL 2961561 (S.D.N.Y. Oct. 20, 2025), the U.S. District Court for the Southern District of New York addressed whether it could remand an ERISA long-term disability claim to the insurer for further review after benefits were terminated. The court declined to order remand but granted Hartford permission to move for summary judgment on the issue of whether the plaintiff failed to exhaust her administrative remedies before filing suit.

Background

Plaintiff S. Lucas received long-term disability (“LTD”) benefits from Hartford Life and Accident Insurance Company beginning in 2021, after claiming a chronic condition prevented her from working. In early 2024, Hartford scheduled her for an independent medical examination (“IME”) to reassess her disability.

Lucas attended the IME but refused to provide photo identification or sign certain paperwork and left the examination before it was completed. A month later, Hartford terminated her benefits, explaining that it could not determine her continued eligibility due to the incomplete IME and advising her that she had 180 days to appeal to the company’s appeals unit at a specified address.

Rather than mail her appeal as directed, Lucas’s counsel emailed an appeal letter to the claims specialist who handled her case. Hartford claimed it never received that email. Months later, when the parties appeared before the court, Hartford located the appeal in its system and offered to review it if the court stayed the litigation and remanded the matter for reconsideration. Lucas declined and continued to pursue her ERISA lawsuit.

The Court Declines to Remand the Claim

Judge Valerie Caproni rejected Hartford’s request to remand the case to the insurer for further administrative review. While remand is the typical remedy when an ERISA insurer’s denial of benefits is found to be procedurally flawed or arbitrary, the court emphasized that remand is a post-merits remedy, not a procedural mechanism available before the merits are decided.

Because no finding had yet been made as to whether Hartford’s termination of benefits was improper, and because Lucas herself opposed remand, the court concluded it lacked authority to order it at this preliminary stage. The judge also noted that remand is ordinarily appropriate after a plaintiff prevails on the merits and the insurer is given an opportunity to reevaluate the claim under the correct standards.

Hartford Permitted to Move for Summary Judgment on Exhaustion

The court did, however, grant Hartford leave to move for summary judgment based on Lucas’s alleged failure to exhaust administrative remedies. Under Second Circuit precedent, ERISA claimants must first pursue the plan’s internal appeals procedures before filing in federal court — a “judicially created exhaustion requirement” designed to promote efficient claim resolution.

Lucas argued that Hartford forfeited any right to further review by failing to respond to her emailed appeal within ERISA’s 45-day deadline. The court rejected that reasoning, explaining that even if the email were sufficient to trigger the appeal process, Hartford’s non-response would have constituted a constructive denial, thereby satisfying the exhaustion requirement — not eliminating it.

Judge Caproni distinguished between “exhaustion,” a prerequisite to bringing suit, and “remand,” a remedy available only after a merits finding in the claimant’s favor. Because exhaustion is a threshold issue, the court determined it must be resolved before reaching the substance of the claim and allowed Hartford to move for summary judgment on that basis.

Next Steps

The court ordered the parties to propose a briefing schedule for Hartford’s forthcoming summary judgment motion and to indicate whether any discovery is needed before that motion is filed. If Hartford’s motion is denied, the case will proceed to a bench trial on the merits, as both parties waived the right to a jury.

Key Takeaways

• Remand Is a Remedy, Not a Pre-Merits Procedure: Courts generally remand ERISA benefit claims to insurers only after finding that the denial was improper. An insurer cannot secure remand to conduct a “do-over” before judicial review, especially where the claimant objects.
• Strict Adherence to Appeal Procedures Matters: The decision underscores the importance of following the insurer’s stated appeal instructions. Sending an appeal to the wrong address—even to a claims handler directly—can give rise to an exhaustion defense.
• Procedural Precision Benefits Both Sides: Judge Caproni noted that both parties’ submissions contained poorly organized and hard-to-read exhibits, emphasizing that clarity in the administrative record and filings is essential in ERISA litigation.
• Practical Impact: For claimants, Lucas serves as a reminder to follow appeal procedures to the letter. For insurers, the ruling limits attempts to remand claims mid-litigation and reinforces the exhaustion requirement as a key procedural safeguard.

How Roberts Disability Law Can Help

If Hartford has denied or terminated your long-term disability benefits, Roberts Disability Law, P.C. can help you navigate the complex ERISA appeals process. Our attorneys have extensive experience challenging Hartford’s claim denials and ensuring that appeals are fully supported by medical, vocational, and legal evidence. We understand the insurer’s tactics and deadlines, and we work to build strong, timely appeals that protect your rights and maximize your chance of benefit reinstatement.