Delaware Federal Court Upholds Denial of Long-Term Disability Benefits Despite SSDI Award

When a former DuPont employee challenged the termination of her long-term disability (LTD) benefits, she argued both that the review process violated ERISA’s procedural protections and that the administrator acted unreasonably in cutting off benefits despite years of approval and a favorable Social Security ruling. But in McDonald v. E.I. Dupont De Nemours and Company Total and Permanent Disability Plan, No. CV 23-1141-RGA, 2025 WL 2733637 (D. Del. Sept. 25, 2025), the court sided with the Plan and its administrator, The Hartford, granting summary judgment in their favor.

Judge Richard Andrews’ opinion illustrates the uphill battle ERISA claimants face under the “arbitrary and capricious” standard of review. The court rejected the plaintiff’s procedural arguments under ERISA § 503 and concluded that substantial evidence supported The Hartford’s decision, even in the face of contrary opinions from her treating physician and a prior Social Security Disability Insurance (SSDI) award.

Procedural Challenge Rejected

McDonald first argued that IMEDECS, the independent reviewer handling her final-level appeal, violated ERISA’s procedural protections by relying on “new evidence” without giving her the chance to respond. ERISA § 503, along with 29 C.F.R. § 2560.503-1(h)(4)(i)–(ii), requires that claimants be provided access to new or additional evidence considered in connection with an adverse determination.

The court was unpersuaded. Judge Andrews noted that McDonald failed to identify any actual “new” evidence relied upon by IMEDECS. Instead, the record showed that IMEDECS conducted a paper review of the same materials already in the administrative record. As the court explained, McDonald herself described IMEDECS as having relied “solely on a paper review” rather than generating new evidence.

Substantial Evidence Supported the Termination

The heart of the dispute concerned whether The Hartford acted arbitrarily and capriciously in terminating McDonald’s LTD benefits after more than four years of payments. Because the Plan gave The Hartford discretionary authority to determine eligibility, the court applied deferential review under Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 110–12 (1989). Under this standard, a denial is arbitrary only if “without reason, unsupported by substantial evidence or erroneous as a matter of law.” Fleisher v. Standard Ins. Co., 679 F.3d 116, 121 (3d Cir. 2012).

The court found substantial evidence supported the denial:

• Medical Reviews: Consulting physicians—including a board-certified neurologist and orthopedic surgeon—concluded that McDonald showed no consistent, objective neurological deficits and could perform sedentary work.
• IMEDECS Findings: The independent reviewer emphasized repeated documentation of normal strength, coordination, and cognitive functioning in her medical records.
• Claimant’s Own Statements: Hartford relied in part on McDonald’s admission that she was considering part-time work, undermining her claim of total disability.

The court also rejected McDonald’s reliance on Miller v. Am. Airlines, Inc., 632 F.3d 837 (3d Cir. 2011), where the Third Circuit faulted an insurer for reversing a prior disability determination without new evidence. Unlike in Miller, Hartford had “materially different information” in 2022, including an Attending Physician Statement with no “work from home” restrictions and McDonald’s own consideration of returning to work.

Treating Physician vs. Paper Review

McDonald argued that Hartford acted unreasonably by crediting non-treating consultants over her treating neurologist, Dr. Jacobs. But the court reiterated the principle from Black & Decker Disability Plan v. Nord, 538 U.S. 822, 834 (2003): administrators are not required to give special deference to treating physicians. Courts have “no warrant” to impose such a treating physician rule.

The fact that Hartford relied on “paper reviews” rather than independent examinations was a factor weighing against the administrator, but not enough to tip the balance. As the court noted, reliance on paper reviews “is another factor to consider in the overall assessment” but does not render a decision arbitrary per se (citing Potts v. Hartford Life & Accident Ins. Co., 272 F. Supp. 3d 690, 710 (W.D. Pa. 2017)).

Social Security Disability Award

Finally, McDonald pointed to her fully favorable SSDI award as proof of disability. The court acknowledged the award but emphasized that an SSDI finding does not bind plan administrators. Citing Balas v. PNC Fin. Servs. Grp., Inc., 2012 WL 681711, at *11 (W.D. Pa. Feb. 29, 2012), the court reiterated that SSDI benefits “do not in themselves establish” that a private plan denial is arbitrary.

Hartford’s denial letter even explained why SSDI and LTD standards diverge: the SSA treats advancing age as a limiting factor and does not conduct transferable skills analyses, while Hartford does. These distinctions were enough to justify the different outcome.

Key Takeaway

This case is a stark reminder that ERISA’s arbitrary and capricious standard is highly deferential to insurers and plan administrators. Courts will uphold denials so long as they are grounded in substantial evidence, even where treating doctors disagree or claimants have been approved for Social Security benefits. For claimants, the decision highlights the importance of building a record with consistent, objective medical evidence that directly addresses the plan’s “any occupation” standard.