Ninth Circuit Affirms Denial of Long-Term Disability Benefits Where Independent Medical Review Process Diminished Weight of Structural Conflict of Interest

In Wallace v. Hartford Life and Accident Insurance Company, No. 25-2716, 2026 WL 1046667 (9th Cir. Apr. 17, 2026), a memorandum disposition, the Ninth Circuit affirmed the district court’s summary judgment in favor of Hartford Life and Accident Insurance Company on Plaintiff’s claim for long-term disability benefits under a group benefit plan purchased by his former employer, Freeport-McMoRan Inc. Wallace v. Hartford Life and Accident Insurance Company, No. CV-23-00071-TUC-JGZ, 2025 WL 963579 (D. Ariz. Mar. 31, 2025). Plaintiff, a mining engineer who had been receiving long-term disability (LTD) benefits since March 2017 based on a fibromyalgia diagnosis, had his benefits terminated by Hartford effective January 4, 2022, following an annual review in which Hartford determined he failed to meet the plan’s “Any Occupation” definition of disability. The Ninth Circuit reviewed de novo the district court’s selection and application of the standard of review.

The panel first confirmed that abuse of discretion review was appropriate because the plan expressly granted Hartford full discretion and authority to determine eligibility for benefits and construe the plan’s terms. Citing Nolan v. Heald College, 551 F.3d 1148, 1154 (9th Cir. 2009), the court reiterated that in ERISA denial-of-benefits cases limited to the administrative record, a motion for summary judgment is merely the vehicle for bringing the legal question before the district court, and the usual summary judgment standards do not apply.

The panel next addressed Hartford’s structural conflict of interest, which arose because Hartford served as both the plan’s administrator and its insurer. The court acknowledged that under Abatie v. Alta Health & Life Insurance, 458 F.3d 955, 959 (9th Cir. 2006) (en banc), abuse of discretion review is accordingly “tempered by skepticism” and the conflict is a factor to be considered. However, citing Metropolitan Life Insurance v. Glenn, 554 U.S. 105, 117 (2008), and Harlick v. Blue Shield of California, 686 F.3d 699, 707 (9th Cir. 2012), the court gave the conflict little weight because Hartford’s determination was supported by the results of a thorough, neutral, and independent review process. As the district court detailed, when the updated medical records submitted by Plaintiff during the annual review period failed to describe any restrictions and limitations or include an attending physician statement, and when Plaintiff’s treating physicians did not respond to Hartford’s repeated requests for clarification, Hartford arranged for an independent medical examination conducted by Dr. Brian McCrary, a board-certified occupational medicine physician, whose examination revealed no restrictions or impairment. 2025 WL 963579, at *5. On appeal of the termination, Hartford retained an independent tri-morbid panel of three board-certified physicians, Drs. Vincent, Kretzmann, and Jasso, each of whom reviewed the full file and concluded there was no basis for restrictions and limitations or cognitive impairment. Id. at *5. When Plaintiff’s counsel responded with an additional opinion letter from his treating physician, Hartford provided that letter to the reviewing doctors, who issued addenda confirming their initial findings, and then afforded Plaintiff an additional opportunity to comment before issuing its final determination. Id.

Finally, the panel held that Hartford did not abuse its discretion in concluding that Plaintiff failed to meet his burden of proving continued entitlement to benefits beyond January 4, 2022. Although the updated medical records Plaintiff submitted did not support his continued eligibility, Hartford went further, developing the record through the independent examination and analyses described above. The district court noted that the most recent medical record from Plaintiff’s treating physician, Dr. Marsh, that supported Plaintiff’s position was an office visit note dated October 23, 2019, and that during the relevant review period, Plaintiff consistently relied on conclusory opinion letters rather than objective medical records or updated testing. Id. at *14. Following receipt of Plaintiff’s criticisms, Hartford engaged in a “meaningful dialogue” with Plaintiff as required by Salomaa v. Honda Long Term Disability Plan, 642 F.3d 666, 676 (9th Cir. 2011), and conducted a full and fair review under 29 U.S.C. § 1133(2). The court found Hartford’s determination and its lengthy explanation of the reasons for denial to be reasonable.