Ninth Circuit Finds Hewlett-Packard Plan Did Not Abuse Its Discretion in Denying Long-Term Disability Benefits

In Alves v. Hewlett-Packard Comprehensive Welfare Benefits Plan, No. 21-55476, 2022 WL 726928 (9th Cir. Mar. 10, 2022), Plaintiff-Appellant Michael Alves appealed the district court’s (Judge Klausner) determination that Sedgwick Claims Management Services, Inc., the claims administrator for the Hewlett-Packard Comprehensive Welfare Benefits Plan, did not abuse its discretion in denying Alves’s claim for long-term disability benefits. The Ninth Circuit, reviewing the district court’s decision de novo, also found that Sedgwick did not abuse its discretion in concluding that Alves was not “Totally Disabled” as defined in the Plan.

The court explained that Alves’s medical records did not show he was unable to perform the duties of his own occupation or any occupation for which he is or may become qualified. Sedgwick relied on several “persuasive medical opinions” from Drs. Taj Jiva, Rizwan Karatela, Heidi Connolly, Stephen Broomes, Brian Strizik, and Frank Polanco, who all concluded that Alves was not disabled. Though Dr. Broomes concluded that Alves was limited to sitting continuously for 30 minutes per hour and another doctor concluded that Alves needed to elevate his legs, the court found that Alves could still perform sedentary work. The court also distinguished the Social Security Administration’s (“SSA”) finding of disability. It explained that SSA was directed by its Medical-Vocational Guidelines to find Alves disabled, regardless of whether Alves had the residual functional capacity to perform “the full range of sedentary work.” Sedgwick was not required to compare and contrast the medical evidence it relied on with that relied on by the SSA since it evaluated SSA’s conclusion and gave a reasonable explanation for departing from it. The court concluded that Sedgwick’s review was thorough and evaluated Alves from a “whole-body” perspective. Affirmed.