Second Circuit Affirms Hartford’s Termination of Long-Term Disability Benefits

In Flowers v. Hartford Life & Accident Ins. Co., No. 23-7259, 2025 WL 33236 (2d Cir. Jan. 6, 2025), involving a dispute over long-term disability benefits (“LTD”), the Second Circuit affirmed the district court’s grant of summary judgment in favor of Hartford Life & Accident Insurance Company, thereby upholding the denial of continuing LTD benefits to Plaintiff-Appellant Flowers.

Flowers, a former Regional Human Resources Manager at Duane Reade, was initially approved for long-term disability benefits by Hartford, the insurer and claims administrator for Duane Reade disability plan. These benefits were paid from 2009 until 2020, when Hartford informed Flowers of the denial of her claim for continued benefits. Flowers appealed administratively, and upon denial, sought relief in the district court. The district court denied her motion for summary judgment and granted Hartford’s cross-motion. Flowers appealed.

Central to the appellate court’s affirmation was the discretionary authority granted to Hartford under the plan. As with many ERISA-governed plans, the terms provided Hartford with “full discretion and authority to determine eligibility for benefits and to construe and interpret all terms and provisions.” This discretionary clause is pivotal, as it necessitates that judicial review of the plan administrator’s decision is limited to an “arbitrary and capricious” standard. Under this deferential standard, a court will uphold the administrator’s decision if it is based on “substantial evidence” and not without reason.

The court found substantial evidence supporting Hartford’s decision. Several medical professionals, including Drs. Liva, Hussain, and Becker, opined that Flowers could work full-time. Even her treating internist, Dr. Pintauro, concurred with this assessment. Although Flowers’s treating rheumatologist and physical medicine specialist did not formally respond to Hartford’s vocational analysis, their notes indicated normal findings and symptom improvement. Furthermore, Flowers herself had not sought mental health treatment since 2018, undermining claims of psychiatric limitations.

Hartford’s Employability Analysis Report (EAR) identified five occupations that Flowers was deemed qualified and capable of performing, considering her education and experience. Although Flowers challenged this report, alleging flaws in the vocational preparation levels assigned, the court determined these inconsistencies were immaterial. The plan defined disability as the inability to perform essential duties of any occupation for which one is qualified, and Flowers’s background rendered her suitable for the positions Hartford identified.

Flowers’s contention that Hartford ignored her vocational evidence was similarly unavailing. The court noted that plan administrators are granted discretion in evaluating the sufficiency of evidence supporting a claimant’s position. In cases where evidence is conflicting, as it was here, administrators are not deemed arbitrary or capricious when they credit their own evaluative processes and conclusions over the claimant’s evidence, unless the evidence overwhelmingly supports the claimant’s position, which it did not in this case.

The court emphasized that Hartford had considered the totality of Flowers’s vocational evidence and found it insufficient to alter the decision. The court underscored that the administrator’s decision would be upheld unless it was unreasonable to deny the claim based on the evidence in the record. Hartford’s decision to rely on its own Employability Analysis Report, which identified viable employment options, was justified within the substantial evidence framework.

In conclusion, the court’s decision serves as a reminder of the significant deference afforded to plan administrators under ERISA when the plan grants discretionary authority. The arbitrary and capricious standard of review poses a substantial hurdle for plaintiffs seeking to overturn benefit denials. For attorneys practicing in the field of ERISA litigation, this case reinforces the critical importance of thoroughly documenting and presenting compelling evidence that directly challenges the plan administrator’s conclusions. Without such robust evidence, courts are likely to defer to the administrator’s judgment, as demonstrated in this case.