Second Circuit: Hartford Did Not Abuse Its Discretion in Denying Long-Term Disability Benefits to Claimant Impaired by Meniere’s Disease

In Nall v. Hartford Life & Accident Ins. Co., No. 22-49, 2023 WL 2530456 (2d Cir. Mar. 16, 2023), the Second Circuit affirmed the district court’s grant of summary judgment to Hartford Life & Accident Insurance Company in this dispute over the denial of long-term disability benefits for the plaintiff, Ashley Nall, who suffers from Meniere’s disease. Nall claimed disability from her occupation as an intake coordinator due to debilitating vertigo, ear congestion, and migraines. The court reviewed Hartford’s decision to deny Nall benefits under the arbitrary and capricious standard of review since the ERISA plan granted Hartford discretionary authority to determine eligibility for benefits.

The court found that Hartford’s decision was not an abuse of discretion because it was supported by substantial evidence. That evidence includes medical records from Nall’s doctor who concluded on multiple occasions that she could reach, sit, engage in keyboarding, and walk or stand. Her doctor also told Hartford that Nall could return to work in the near future. It was not until after Nall’s appeal was submitted that her doctor opined that Nall was disabled and could not work. Hartford also relied on the reviews of four medical professionals who reviewed Nall’s records and concluded that she could work. The court found these reviews to be supported by the record. Further, the court found that in denying Nall’s claim, Hartford did not disregard her subjective complaints or unreasonably rely on the review of its doctor over the opinion of her treating doctor. The issue is not whether there is evidence of Nall’s disability, but rather, whether Hartford had a “reasonable basis” for denying benefits. The court concluded that Hartford had such a basis.