District Court Denies Summary Judgment in ERISA Benefits Matter Where Hartford Failed to Meaningfully Engage with Evidence Supporting Disability

In Butter v. Hartford Life and Accident Insurance Company, No. 24-11499-MJJ, —F.Supp.3d—-. 2026 WL 172049 (D. Mass. Jan. 22, 2026), the District of Massachusetts denied cross-motions for summary judgment and remanded an ERISA long-term disability claim after concluding that Hartford Life and Accident Insurance Company failed to conduct a reasoned and evidence-based review of the claimant’s entitlement to benefits. Although the court applied deferential abuse-of-discretion review, it found that Hartford’s termination decision was not supported by substantial evidence and failed to meaningfully engage with extensive medical evidence supporting disability.

The plaintiff, a Director of Student Support, was covered under a Hartford-issued group long-term disability policy. After stopping work in March 2021 due to chronic neck and leg pain, fibromyalgia, radiculopathy, and related conditions, Butter was approved for LTD benefits during the policy’s “own occupation” period. Hartford later terminated benefits when the claim transitioned to the more stringent “any occupation” standard, concluding that Butter retained the functional capacity to perform full-time work in several alternative occupations.

As a threshold matter, the court addressed Hartford’s structural conflict of interest, given its dual role as both claim adjudicator and payor. Relying on recent First Circuit precedent, the court afforded the conflict little weight, emphasizing that Hartford employed third-party vendors to select reviewing physicians and used a separate appeals unit to review the initial termination. The court found no evidence of procedural irregularities, shifting explanations, or bad-faith claims handling that would warrant heightened scrutiny.

Nevertheless, the court determined that Hartford’s substantive evaluation of the record was deeply flawed. Central to Hartford’s termination decision was surveillance footage obtained over several days in mid-2022. The court criticized Hartford for assigning outsized weight to these recordings, which captured only fleeting moments—often less than a minute at a time—of the claimant performing limited activities such as carrying items, bending briefly, or walking short distances. While Hartford’s descriptions of the footage were technically accurate, the court emphasized that the insurer failed to account for the brevity of the observations, the claimant’s slow gait, and the visible effort involved in her movements. Citing prior district precedent, the court reiterated that disability determinations may be arbitrary and capricious when administrators give undue weight to isolated activities divorced from their broader context.

The court was equally critical of Hartford’s reliance on a single independent medical examination that concluded Butter could sit, stand, and walk for extended periods and sustain full-time work. That opinion sharply conflicted with the assessments of multiple treating physicians, including Butter’s primary care physician and pain specialist, both of whom consistently documented chronic pain, functional limitations, and an inability to tolerate sustained work activity. The court underscored that while plan administrators are not required to defer to treating physicians, they may not simply ignore or discount contrary evidence without explanation. Hartford’s decision letters failed to articulate why the treating physicians’ opinions were rejected or why the IME’s conclusions were entitled to greater weight.

On appeal, Butter submitted additional evidence, including a functional capacity evaluation and an independent IME finding her incapable of performing even sedentary work on a sustained basis. Although Hartford obtained another physician record review, the court found that the appeal-level analysis suffered from many of the same defects. The reviewing physician acknowledged Butter’s complex medical history and imposed significant restrictions, yet nevertheless concluded—without adequate explanation—that these limitations were compatible with full-time employment. The court found this reasoning internally inconsistent and insufficiently supported.

The court also faulted Hartford for its treatment of Butter’s Social Security Disability Insurance award. While Hartford acknowledged the SSDI determination, it dismissed its relevance with boilerplate language asserting that different standards and evidence may apply. The court held that such generalized statements were inadequate, particularly where Hartford failed to identify any meaningful differences between the medical evidence relied upon by the SSA and the evidence in the ERISA record.

Although the court expressed strong concerns about Hartford’s decision-making process and noted that it was “inclined” to rule in the claimant’s favor, it declined to award benefits outright. Instead, the court remanded the claim to Hartford for further review, concluding that Butter had not yet received the full and fair review required under ERISA.