SSA Disability Award Does Not Entitle ERISA Claimant to Relief from Adverse Judgment

In Pistilli v. First Unum Life Insurance Co., No. 24 Civ. 5266 (AKH), 2026 WL 836647 (S.D.N.Y. Mar. 25, 2026) the plaintiff, after losing her ERISA long-term disability benefits case at trial, obtained a favorable Social Security disability determination and moved to reopen the district court judgment. The court denied the motion, holding that the SSA’s award neither qualified as newly discovered evidence nor would have changed the outcome of the ERISA adjudication.

Background

Pistilli sued First Unum Life Insurance Company under ERISA after the insurer denied her claim for long-term disability benefits following a motor vehicle accident on July 8, 2022. Following a bench trial at which Pistilli testified, the district court issued findings of fact and conclusions of law concluding that First Unum had not acted in an arbitrary and capricious manner in denying the claim, and that substantial evidence supported the insurer’s decision. The court entered judgment in favor of First Unum on October 7, 2025. Pistilli appealed on November 6, 2025, and that appeal remains pending in the Second Circuit.

On November 15, 2025 — roughly five weeks after judgment entered — the Social Security Administration issued a decision finding Pistilli severely disabled as a result of the same 2022 motor vehicle accident. Pistilli moved for relief from judgment on December 15, 2025 under Federal Rule of Civil Procedure 60(b)(2) (newly discovered evidence) and, alternatively, sought an indicative ruling under Rule 62.1(a)(3) that the court would grant the motion if the Second Circuit remanded for that purpose.

Analysis

The court addressed three issues.

First, on the jurisdictional question, the court agreed with Pistilli’s own concession that it lacked jurisdiction to grant a Rule 60(b) motion while the appeal was pending, as the filing of a notice of appeal divests the district court of control over the aspects of the case involved in the appeal. The court turned instead to whether it would grant an indicative ruling under Rule 62.1(a).

Second, on the Rule 60(b)(2) newly discovered evidence question, the court found that the SSA decision failed on at least two independent grounds. The rule requires that newly discovered evidence consist of facts that existed at the time of trial. The SSA decision was issued after trial concluded, and therefore did not qualify. Beyond that threshold defect, the court held that even if the SSA decision were treated as newly discovered evidence, it would not have changed the outcome. The SSA applied a different standard of analysis to the same factual record and reached a different conclusion — but that divergence had no bearing on the court’s own assessment under ERISA’s arbitrary and capricious standard.

Third, on the Rule 60(b)(6) catchall argument, the court rejected Pistilli’s attempt to reframe the motion under that provision. Because her claims were properly characterized under Rule 60(b)(2), she could not invoke the catchall clause. And even if she could, the result would be the same: the SSA award would not have changed the outcome of the litigation.

Takeaway

This decision illustrates a recurring and frustrating dynamic for disability claimants: a Social Security Administration finding of total disability, though highly significant in the administrative context, carries no weight in ERISA litigation and cannot serve as a basis to reopen an adverse district court judgment. The court’s reasoning underscores how completely siloed the two systems remain — the same disabling condition, evaluated on the same facts, can produce opposite results under different legal standards, with neither determination binding the other. Pistilli’s appeal of the underlying merits ruling remains pending in the Second Circuit.