District of Maine Recommends Judgment for Reliance Standard, Concluding Claimant Could Perform Sedentary Claims Supervisor Occupation

In Shortill v. Reliance Standard Life Insurance Company, No. 2:25-cv-00264-JAW, 2026 WL 1179948 (D. Me. Apr. 30, 2026), U.S. Magistrate Judge John C. Nivison issued a Recommended Decision granting Reliance Standard’s motion for judgment on the administrative record and denying Plaintiff’s cross-motion in this ERISA Section 502(a)(1)(B) action challenging the termination of long-term disability benefits. Applying the arbitrary and capricious standard, the court concluded that substantial evidence supported Reliance Standard’s determination that Plaintiff was no longer Totally Disabled from her Regular Occupation as a claims supervisor as of April 19, 2024.

Plaintiff worked as a claims supervisor for TRISTAR when, on July 28, 2023, she fell backward down a flight of stairs, sustaining a non-displaced C7 spinous process fracture, bilateral shoulder injuries, and a concussion. The C7 fracture healed conservatively, confirmed as “solidly healed” by Dr. James Kang in January 2024. Plaintiff underwent arthroscopic right rotator cuff repair in October 2023 and engaged in physical therapy through April 2024. On April 19, 2024, PA-C Kelly Collins documented that Plaintiff’s right shoulder rehabilitation was “going very well,” her pain was 2/10, and cleared her for progressive lifting while advising her to “avoid heavy repetitive lifting if returning to work.” Reliance Standard’s nurse reviewer, vocational consultant Shelly Icardi, and on appeal, board-certified orthopedic surgeon Dr. Ashish Anand all concluded Plaintiff retained sedentary work capacity from April 19, 2024 forward. Reliance Standard terminated benefits effective April 19, 2024, and upheld the termination on appeal. Plaintiff’s position with TRISTAR had been eliminated in a March 15, 2024 layoff, and she later underwent cervical microdiscectomy and fusion on June 26, 2024 for a worsening C6-7 disc herniation, but the carrier declined to reopen the claim, finding the gap between April 19 and June 11, 2024 was not bridged by continuous disability and that coverage had terminated upon the layoff.

Did Reliance Standard Adequately Consider the Claimant’s Mental Health Condition?

Plaintiff argued that Reliance Standard violated ERISA’s full and fair review requirement under 29 U.S.C. § 1133(2) and 29 C.F.R. § 2560.503-1(h)(2)(iv) by failing to consider her deteriorating mental health and by not referring her claim for a behavioral health review. The court rejected this argument. The record reflected that both Nurse Bohnsack at the pre-appeal level and Dr. Anand on appeal expressly considered Dr. Pamela Schultze’s April 10, 2024 office note documenting Plaintiff’s moderate recurrent major depressive disorder and the medication adjustment that followed. More fundamentally, the court emphasized that the burden of proving disability rests with the claimant under Morales-Alejandro v. Med. Card Sys., Inc., 486 F.3d 693, 700 (1st Cir. 2007), and that Plaintiff did not assert a mental health basis for disability in her application for benefits, did not raise psychological concerns in conversations with the claims examiner, and offered no evidence that she pursued treatment with a mental health provider during the relevant period. The court concluded there were “no records or opinions that suggest that Plaintiff’s mental health condition precluded her from working as a claims supervisor.”

Was Reliance Standard’s Medical Review Improperly Siloed or Narrowed to a Single Time Window?

Plaintiff contended that Reliance Standard engaged in a “siloed analysis” of her injuries, isolating her right shoulder recovery while disregarding the combined effects of her cervical spine injury and bilateral shoulder pathology, and that it unreasonably directed Dr. Anand to focus solely on the period from April 19, 2024 to June 11, 2024. The court rejected both contentions. Nurse Bohnsack’s reviews considered the full arc of Plaintiff’s treatment, including the C7 fracture’s spontaneous healing, the left elbow lateral epicondylitis and occupational therapy course, the June 2024 reemergence of cervical symptoms culminating in fusion surgery, and the October 2024 left shoulder MRI findings. Dr. Anand similarly considered records from August 2023 through October 2024. The court found that Reliance Standard’s particular focus on the April 19 to June 11, 2024 period was logical rather than arbitrary, because Plaintiff’s TRISTAR position had been terminated in March 2024 and her Policy coverage ended at the end of that month, making continuous disability through June 11, 2024 the dispositive eligibility question for any claim premised on the subsequent cervical surgery.

Did Substantial Evidence Support the Vocational Determination That the Claimant Could Perform Her Regular Occupation?

Plaintiff challenged the vocational analysis on the ground that Dr. Anand had restricted her from any pushing or pulling with her right arm, an activity she contended was required for sedentary work. She also characterized Ms. Icardi’s two vocational reports as internally inconsistent. The court acknowledged “some tension” between Ms. Icardi’s description of the claims supervisor occupation as involving occasional pushing and pulling and her conclusion that the occupation “does not typically involve pushing or pulling activities,” but found the opinions and the resulting determination supportable. Citing Brigham v. Sun Life of Canada, 317 F.3d 72, 78 (1st Cir. 2003), the court reiterated that sedentary work under the Dictionary of Occupational Titles involves only occasional exertion of up to ten pounds. The court emphasized, citing McDonough v. Aetna Life Ins. Co., 783 F.3d 374, 380 (1st Cir. 2015) and Bernitz v. Usable Life, 149 F.4th 113, 125 (1st Cir. 2025), that the relevant inquiry is whether substantial evidence supported Plaintiff’s ability to perform the material duties of a claims supervisor as performed in the national economy, not whether she could perform every theoretical aspect of a sedentary occupation. Notably, Dr. Anand himself concluded Plaintiff was “quite capable of working with restrictions and limitations from 04/19/2024 and ongoing” and “capable of doing Sedentary level work.”

How Did the Court Weigh Reliance Standard’s Structural Conflict of Interest?

Plaintiff argued that Reliance Standard’s dual role as funder and claims fiduciary warranted heightened scrutiny under Metropolitan Life Insurance Co. v. Glenn, 554 U.S. 105 (2008). The court afforded the structural conflict little weight in the Glenn multi-factor analysis. Reliance Standard had insulated the determination process by employing third-party peer reviewers and an independent appeals unit, and Plaintiff had not pointed to any evidence suggesting the conflict influenced the decision. Citing the First Circuit’s recent decision in Bernitz v. Usable Life, 149 F.4th 113, 122-23 (1st Cir. 2025), the court found this structural posture analogous to other administrators afforded deference where claimants failed to carry the burden of showing actual influence under Troiano v. Aetna Life Insurance Co., 844 F.3d 35, 45 (1st Cir. 2016).

The Magistrate Judge recommended that the District Court deny Plaintiff’s motion for judgment on the administrative record and grant Reliance Standard’s motion.