District Court Finds Reliance Standard Did Not Abuse Its Discretion in Applying 24-Month Mental Illness Limitation in Traumatic Brain Injury Claim

In Hall v. Reliance Standard Insurance Company, No. CV 23-20761 (ZNQ) (RLS), 2025 WL 1233203 (D.N.J. Apr. 29, 2025), on cross-motions for summary judgment, New Jersey District Judge Zahid N. Quirashi granted judgment in favor of Defendant Reliance Standard Insurance Company, finding that Reliance had not abused its discretion in terminating benefits after 24 months based on its application of the mental illness limitation contained in the ERISA-governed long-term disability (“LTD”) policy.

Plaintiff Hall, a registered nurse, had been employed by Robert Wood Johnson University Hospital and was covered under its long-term disability plan administered by Reliance. Following a severe motor vehicle accident in 2015, Ms. Hall suffered multiple injuries, including a traumatic brain injury. She was initially awarded long-term disability benefits in 2016 after demonstrating “Total Disability” in her role as a clinical nurse instructor. However, under the plan, the definition of disability changes after 24 months to require the inability to perform “Any Occupation,” and benefits for disabilities caused by mental or nervous disorders are also capped at 24 months. Reliance terminated Ms. Hall’s benefits in 2020, arguing that her continued impairments were primarily psychiatric and thus subject to the 24-month limitation.

In reviewing the parties’ cross-motions, the court’s analysis began with the summary judgment standard. Summary judgment is appropriate when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law. The court emphasized its role in evaluating whether there was a genuine dispute for trial rather than weighing evidence or determining credibility. Additionally, for ERISA claims, the court noted that the standard of review depends on the plan’s terms. Here, because the plan granted Reliance discretionary authority, the court reviewed the denial of benefits under the “arbitrary and capricious” standard. This deferential standard requires that the decision be upheld unless it lacks reason, is unsupported by substantial evidence, or is erroneous as a matter of law.

Central to the court’s decision was the plan’s “Mental or Nervous Disorders” limitation. Under this provision, benefits are limited to 24 months for disabilities caused or contributed to by such disorders. To continue receiving benefits beyond this period, Ms. Hall needed to establish ongoing total disability due to a physical condition alone. Reliance found that Ms. Hall had not satisfied this burden. Reliance’s determination was based on an independent medical examination as well as several medical reviews, all of which concluded that Ms. Hall’s impairments were principally psychiatric rather than physical. Specifically, Dr. Kutner, a neuropsychologist, concluded that Ms. Hall suffered from cognitive impairment, somatic symptom disorder and PTSD, while other specialists found no substantial physical limitations preventing her from working.

Ms. Hall contended that her cognitive issues were due to physical brain injuries from her accident, and did not have origin in any psychiatric condition. Plaintiff further asserted that Reliance improperly weighed the opinions of non-treating physicians over her treating doctors. However, the court noted that plan administrators are not required to give special deference to treating physicians, as established by the Supreme Court in Black & Decker Disability Plan v. Nord.

The court found that Reliance’s decision to terminate benefits was neither arbitrary nor capricious. The insurer had reasonably concluded, based on substantial evidence from independent medical experts, that Ms. Hall’s impairments were primarily psychiatric. Therefore, the 24-month limitation applied, and Ms. Hall failed to demonstrate a physical disability preventing her from performing any occupation. The decision provides an insightful examination of the interplay between mental and physical disability claims under ERISA, as well as the standard of review applicable to plan administrator decisions. If Reliance or your disability insurer has denied or otherwise limited your ERISA benefits claim, contact us for assistance.