Seventh Circuit Affirms Hartford’s Termination of Long-Term Disability Benefits Based on Opinions from Non-Examining Doctors

In Oye v. Hartford Life & Accident Ins. Co., No. 24-2925, —F.4th—-, 2025 WL 1659281 (7th Cir. June 12, 2025), the Seventh Circuit Court of Appeals upheld the district court’s decision that Plaintiff-Appellant Oye was not entitled to long-term disability benefits under the ERISA plan administered by Hartford Life. Though Hartford Life had found Plaintiff was disabled for four years from fibromyalgia, it relied on consultative doctors who never evaluated Plaintiff in person to determine that she was no longer disabled due to her chronic pain condition. In upholding the denial of benefits, the court found that the district court was not required to weigh Hartford Life’s past finding of disability.

Plaintiff was a director at PricewaterhouseCoopers before her fibromyalgia, along with depression and anxiety, rendered her unable to work. She applied for long-term disability benefits under the PwC disability plan, insured by Hartford Life. Hartford Life initially approved her claim but later terminated the benefits, asserting that Plaintiff was no longer disabled based on consultative reviews.

The district court performed a de novo review of the case, meaning it independently evaluated the evidence without deference to Hartford’s previous disability determination. The court found that the medical evidence provided by Hartford’s consultative doctors, who concluded Oye was not disabled, was more detailed and persuasive than the letters from Oye’s treating physicians.  The court highlighted that for Oye to qualify for benefits, her disability needed to be solely due to physical conditions. Evidence suggested her mental health issues significantly contributed to her limitations, thus disqualifying her under the plan’s terms.

The Seventh Circuit found no clear error in the district court’s factual findings, as the decision was supported by substantial evidence from the record. The court emphasized that the district court’s approach was correct, as it did not accord special deference to the opinions of treating physicians over those of consultative examiners. The district court was not required to give weight to Hartford Life’s past finding of disability. Additionally, the court noted that the district court was not required to discuss every piece of evidence, such as a 2017 consultative report that supported Oye’s claim, especially when more recent evaluations showed improvement. For these reasons, the court affirmed the decision of the district court in favor of Hartford Life.