Court Awards Short Term Disability Benefits Against Intel Disability Plan, Remands Long Term Disability Claim After Finding Claims Administrator Abused Discretion by Dismissing Treating Physicians’ Opinions

In Gupta v. Intel Short-Term Disability Plan, No. 25-cv-00871-NC, 2026 WL 821590 (N.D. Cal. Mar. 25, 2026), an ERISA action arising from the denial of short-term disability (“STD”) and long-term disability (“LTD”) benefits, the Northern District of California granted the plaintiff judgment on his STD claim, remanded the LTD claim for further administrative consideration, and granted the defendants judgment on the CA-VSTD plan claim and breach of fiduciary duty claim.

Gupta, a Cloud Software Development Engineer at Intel, sought disability benefits beginning in early 2022, submitting records from a psychiatrist, a chiropractor, and an acupuncturist/functional medicine physician documenting high anxiety, vestibular dysfunction, sleep disturbance, dizziness, and impaired concentration. Reed Group, the third-party claims administrator, initially approved benefits but terminated them in October 2022 following a peer review by psychiatrist Stuart Gitlow, who acknowledged the treating physicians’ documented functional deficits but concluded the records lacked sufficient clinical detail. On appeal, Reed obtained additional peer reviews from psychiatrist Fariha Qadir and internist Steven Winkel. After the plaintiff submitted further testing — including tilt-table, MoCA, Total Brain, and QEEG results — both reviewers issued addendums affirming their original conclusions. Reed issued a final denial in January 2023. The plaintiff then sought to initiate an LTD claim, but Reed refused on the basis that the STD denial meant the plaintiff had not satisfied the fifty-two-week elimination period. Intel terminated the plaintiff in August 2023.

The court first dismissed the CA-VSTD plan claim for failure to exhaust administrative remedies, finding the requirement to appeal to the California Employment Development Department both mandatory and unambiguous. Applying abuse of discretion review — Intel having unambiguously delegated sole discretionary authority to Reed under the plan — the court turned to the STD denial. On the question of job description, the court found no error, as Reed and its consulting physicians had used the plaintiff’s own description of his duties and the plan required only that Reed assess whether the plaintiff could perform his regular and customary work.

The court found abuse of discretion on the treating physician issue. The plan’s peer reviewers acknowledged the treating physicians’ documented findings — including high anxiety, vestibular dysfunction, sleep disturbance, dizziness, and impaired concentration and communication — yet dismissed them without identifying reliable contradictory evidence. Qadir concluded the plaintiff had no functional impairments despite acknowledging documented subjective symptoms, reasoning in part that the plaintiff was not “actively or acutely suicidal, homicidal, psychotic, manic, or aggressive.” The court rejected this framing, drawing on James v. AT&T W. Disability Benefits Program, 41 F. Supp. 3d 849 (N.D. Cal. 2014), to explain that a plan cannot demand that a claimant suffering from debilitating anxiety also present with acute psychiatric crisis indicators as a condition of receiving benefits. Winkel, an internist who expressly acknowledged that psychological impairment fell outside his specialty, nevertheless twice stated the plaintiff had never undergone psychiatric evaluation — ignoring that the plaintiff had been seeing psychiatrist John Faber monthly throughout the claim — and dismissed the additional testing the plaintiff submitted on appeal, including tilt-table, MoCA, Total Brain, and QEEG results, without explanation. The court further noted that Winkel’s MoCA analysis acknowledged the plaintiff’s score fell below the normal range indicating mild cognitive defect, yet he failed to address the remaining test results at all.

Citing the principle that courts must consider the unique nature of psychiatric disabilities, which often involve subjective complaints not reducible to discrete clinical markers, the court held that the plan arbitrarily dismissed the treating physicians’ opinions while pointing only to the absence of certain imprecise indicators — precisely the kind of reasoning condemned in James. Finding that no new evidence could produce a reasonable conclusion permitting denial and that remand would therefore be a useless formality, the court awarded STD benefits from September 30, 2022, through February 24, 2023.

On the LTD claim, the court remanded for further record development — including a vocational report — noting that the LTD plan applies a different disability definition and that no administrative record existed for the period beyond February 2023. The breach of fiduciary duty claim failed because the Intel entity defendants took no fiduciary actions and the claim was duplicative of the LTD benefits claim.