District Court Upholds Hartford’s Termination of Long-Term Disability Benefits Despite Social Security Award

In Engweiler v. Howmet Aerospace Inc., No. 1:24-CV-975, 2025 WL 2318464 (W.D. Mich. Aug. 12, 2025), the U.S. District Court for the Western District of Michigan upheld Hartford Life and Accident Insurance Company’s decision to terminate long-term disability (LTD) benefits for the plaintiff, an engineer suffering from chronic back pain. The court’s ruling underscores how difficult it can be for claimants to prevail when challenging benefit denials under ERISA’s deferential “arbitrary and capricious” standard of review.

Background: From Chronic Back Pain to LTD Benefits

Plaintiff, A. Engweiler, had struggled with back pain for years before undergoing lumbar fusion surgery in 2020. Initially, the surgery improved his condition, but by spring 2021, his pain had intensified to the point that he could no longer sustain full-time work. His orthopedic surgeon, Dr. Mark Moulton, imposed strict restrictions—limiting Engweiler’s ability to sit, stand, or walk for more than an hour each day—and Hartford approved his LTD claim under the plan’s “own occupation” standard, which focuses on whether the claimant can perform their specific job duties.

A Favorable Social Security Decision Before the Stricter “Any Occupation” Review

In 2023, Engweiler secured Social Security Disability Insurance (SSDI) benefits after an Administrative Law Judge credited Dr. Moulton’s longstanding assessment of severe functional limitations. The ruling recognized that someone with Engweiler’s outstanding work history was unlikely to stop working unless truly disabled.

However, Hartford’s LTD policy shifted to an “any occupation” definition of disability after 24 months, requiring Engweiler to prove that he could not perform any job consistent with his training, education, or experience. This change triggered Hartford’s review of his ongoing eligibility.

Hartford’s Termination: Reliance on IME and Vocational Review

Hartford commissioned an independent medical examination (IME) by orthopedic surgeon Dr. John Anderson, who found that while Engweiler had some reduced spinal range of motion, there were “no functional deficits” preventing him from working in sedentary or light-duty positions. Based on this, Hartford terminated his benefits in December 2023.

Engweiler appealed, submitting updated treatment notes reiterating Dr. Moulton’s severe restrictions. Hartford responded by obtaining a file review from Dr. Jamie Lewis, who echoed Dr. Anderson’s conclusions and discounted Dr. Moulton’s opinions as unsupported by “objective findings.” A vocational expert then identified numerous sedentary engineering and management positions available in the national economy. Hartford upheld the termination.

Court Upholds Hartford’s Decision Under ERISA

The court reviewed Hartford’s decision under the “arbitrary and capricious” standard because the plan granted the insurer discretionary authority. Although Engweiler argued that Hartford improperly discounted his treating physician’s opinion and disregarded the SSDI award, the court held that ERISA administrators are not bound by Social Security decisions and may weigh medical opinions differently.

Crucially, Hartford’s reliance on an IME, comprehensive review of the record, and detailed explanation for rejecting contrary evidence demonstrated a “reasoned and principled” decision-making process. The court thus upheld Hartford’s denial of benefits.

Key Takeaways for Disability Claimants

This decision highlights the significant hurdles LTD claimants face under ERISA:

• Stricter Standards After 24 Months: The shift from “own occupation” to “any occupation” definitions often leads to terminations, even for individuals who cannot return to their previous careers.
• Social Security Approval Isn’t Controlling: While helpful, an SSDI award does not guarantee success in an ERISA claim. Insurers often argue that different standards apply.
• Importance of Objective Evidence: Courts frequently uphold insurers’ decisions when they rely on IMEs or vocational analyses over subjective reports of pain and treating physicians’ opinions.

For claimants, Engweiler is a reminder that success often requires building a record with strong, objective support for functional limitations and preparing for insurers’ heightened scrutiny after two years of benefits.