Western District of Kentucky Remands LTD Claim After LINA’s Administrative Failure

In Chalk v. Life Insurance Company of North America, No. 3:25-CV-133-RGJ, 2025 WL 3006758 (W.D. Ky. Oct. 27, 2025), the court addressed a familiar issue in ERISA litigation—how to handle a claim administrator’s failure to timely decide a disability claim. The case highlights the consequences of procedural lapses in claim handling and reinforces that remand, not immediate benefits, is typically the appropriate remedy when no administrative record exists.

Background

Plaintiff Jennifer Chalk filed a claim for long-term disability (“LTD”) benefits with LINA on October 30, 2024, after previously receiving short-term disability (“STD”) benefits for complications related to her right leg amputation. Due to an internal mistake, Life Insurance Company of North America (“LINA”) misfiled her LTD claim materials in her STD claim file and never opened a separate LTD claim for review.

Despite ERISA regulations requiring a disability benefit decision within 45 days, LINA neither issued a decision nor sought an extension. When Chalk inquired months later, she was told no LTD claim existed. She then filed suit under 29 U.S.C. § 1132(a) for breach of contract and benefits due.

Only after the lawsuit was filed did LINA open a review of her LTD claim. LINA then moved to remand the case to complete the administrative process, while Chalk argued that LINA’s procedural violation warranted judicial determination of her entitlement to benefits.

The Court’s Decision

Judge Rebecca Grady Jennings granted LINA’s motion for administrative remand but denied its request for a stay. The court held that although LINA violated ERISA’s notice requirements, remand was appropriate because the record lacked any substantive LTD review.

Citing Hackney v. Lincoln Nat’l Life Ins. Co., 2012 WL 13343 (W.D. Ky. Jan. 4, 2012), and Sixth Circuit precedents such as Elliott v. MetLife, 473 F.3d 613 (6th Cir. 2006), and Shelby County Healthcare Corp. v. Majestic Star Casino, 581 F.3d 355 (6th Cir. 2009), the court reiterated that remand is proper where a plan administrator’s procedural errors undermine the integrity of the decision-making process. Because LINA never made a benefits determination and the administrative record was incomplete, the court declined to conduct a de novo review.

The court emphasized that Chalk’s STD record could not substitute for an LTD review since the definitions of “Disability” differed—LTD benefits required proof of inability to perform the “material duties” of her regular occupation even with reasonable accommodation.

Attorney’s Fees and Further Proceedings

While remanding, the court recognized Chalk’s eligibility for attorney’s fees under 29 U.S.C. § 1132(g)(1), citing Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242 (2010). The remand itself constituted “some degree of success on the merits.” Chalk was granted leave to move for fees, costs, and past-due benefits by November 14, 2025, though the court declined to order interim benefit payments or a stay.

Key Takeaways for Practitioners & Claimants

• Procedural errors still trigger remand: Courts in the Sixth Circuit continue to favor administrative remand when a claim administrator fails to issue a timely decision, even if the delay violates ERISA’s 45-day rule.
• No de novo shortcut: Even where an STD record exists, courts require a separate LTD review if the definitions or evidence differ materially.
• Fee eligibility from remand orders: Claimants achieving remand may recover attorney’s fees but must still satisfy the Schwartz v. Gregori five-factor test to obtain an award.
• Importance of internal process integrity: The decision underscores that a procedural lapse—such as misfiling a claim—can lead to litigation, fee exposure, and reputational harm for the insurer.