District Court Upholds Hartford’s Termination of Long-Term Disability Benefits Under “Any Occupation” Standard

In Portier v. Hartford Life And Accident Insurance Company, No. CV 24-1717, 2026 WL 45078 (E.D. La. Jan. 7, 2026), the United States District Court for the Eastern District of Louisiana granted judgment in favor of Hartford Life and Accident Insurance Company, upholding its termination of long-term disability (“LTD”) benefits after the claimant’s policy transitioned from an “own occupation” to an “any occupation” standard. Applying the highly deferential abuse-of-discretion standard, the court concluded that Hartford’s decision was supported by substantial evidence, even in the face of competing medical opinions and significant self-reported symptoms.

Background and Policy Terms

Plaintiff Portier received LTD benefits beginning in February 2021 under an ERISA-governed policy issued and administered by Hartford. For the first 24 months following the elimination period, the policy defined disability under an “own occupation” standard, requiring proof that the claimant could not perform the essential duties of his regular occupation. After that 24-month period, however, the definition narrowed significantly: to continue receiving benefits, Portier had to establish that he was unable to perform the essential duties of any occupation for which he was reasonably qualified by education, training, or experience.

The policy expressly granted Hartford discretionary authority to interpret the policy and determine eligibility for benefits, triggering abuse-of-discretion (arbitrary and capricious) judicial review.

Hartford’s Termination Decision

As the claim approached the 24-month transition point, Hartford reevaluated Portier’s eligibility. The record reflected that Portier suffered from serious medical conditions, including coronary artery disease and chronic angina. His treating cardiologist, Dr. Vinod Nair, repeatedly opined that Portier was unable to work in any capacity due to his cardiac condition and related symptoms.

Hartford nevertheless relied on opinions from independent reviewing physicians, including Dr. Darius Marhamati and later Dr. David Friedman, both board-certified cardiologists. While these reviewers agreed that Portier had medically determinable impairments and some functional limitations, they concluded that the objective evidence did not support a complete inability to work. Instead, they opined that Portier could perform full-time sedentary work with restrictions.

Hartford also commissioned an Employability Analysis Report (“EAR”) identifying sedentary occupations existing in the national economy that Hartford believed Portier could perform, including a maintenance superintendent role. Based on this evidence, Hartford determined that Portier no longer met the policy’s “any occupation” definition of disability and terminated benefits effective February 2, 2023.

Administrative Appeal and Litigation

Portier appealed the termination, submitting a detailed affidavit describing his symptoms, medication side effects, and the role stress played in triggering his cardiac episodes. He also submitted updated materials from Dr. Nair reiterating that Portier was incapable of gainful employment. Hartford obtained an additional independent physician review from Dr. Friedman, who again concluded that while Portier was impaired, he retained the capacity for sedentary work on a full-time basis.

Hartford upheld its termination decision on appeal. Portier then filed suit under ERISA § 502(a)(1)(B), arguing that Hartford’s decision was arbitrary and capricious because it allegedly failed to properly consider his subjective complaints, relied on flawed medical reviews, discounted the treating physician’s opinion, and used an unrealistic employability analysis.

Court’s Analysis

The district court emphasized the deferential nature of abuse-of-discretion review, reiterating that its role was not to decide whether Hartford made the best or correct decision, but only whether the decision fell within a continuum of reasonableness supported by substantial evidence.

The court rejected Portier’s argument that Hartford ignored his self-reported symptoms, noting that the administrative record contained numerous references to his complaints and that Hartford expressly stated it considered his personal statements. Although one reviewing physician noted difficulty locating Portier’s appeal letter, the court found that the substance of Portier’s complaints was nevertheless reflected throughout the medical records reviewed.

The court also reaffirmed Fifth Circuit precedent holding that ERISA does not impose a treating-physician rule. Hartford was therefore permitted to credit its independent reviewers over Dr. Nair, even though Dr. Nair consistently supported disability. Conflicting medical opinions alone, the court explained, do not render a decision arbitrary and capricious.

Finally, the court rejected procedural unreasonableness arguments based on Hartford’s structural conflict of interest as both insurer and administrator. Distinguishing cases where insurers ignored or withheld critical evidence, the court found no indication that Hartford failed to consider relevant materials or deprived Portier of a meaningful appeal.

Because substantial evidence supported Hartford’s determination that Portier could perform sedentary work in at least one occupation, the court granted Hartford’s motion for judgment on the administrative record and denied Portier’s cross-motion.

Takeaway for LTD Claimants

This decision underscores how difficult it can be for disabled workers to continue receiving long-term disability benefits once a policy shifts from an “own occupation” to an “any occupation” standard—especially when the insurer has discretionary authority. Even serious medical conditions and strong treating-physician support may not be enough if the insurer can point to file-reviewing doctors and vocational assessments suggesting sedentary work capacity.

For claimants, this case highlights the importance of building a detailed administrative record before benefits are terminated, including clear functional capacity evidence, stress-related limitations, and comprehensive physician opinions that directly address “any occupation” criteria. Experienced ERISA counsel can help ensure that insurers are held accountable for selective reviews, flawed vocational analyses, and procedural shortcuts—often long before a case ever reaches court.