When ERISA Benefits End After Years of Payment: Minnesota Court Upholds Aetna’s Termination of Long-Term Disability Benefits

In Young v. Aetna Life Insurance Company, No. 24-CV-4611 (PJS/DTS), 2026 WL 2874085 (D. Minn. Sept. 24, 2026), U.S. District Judge Patrick J. Schiltz granted summary judgment to Aetna and upheld the termination of long-term disability benefits under an ERISA-governed plan, dismissing the participant’s complaint with prejudice. Plaintiff, a former Senior Business Management Specialist at TD Bank, had received benefits for roughly seven years after being diagnosed with Cyclic Vomiting Syndrome and related metabolic brain damage before Aetna terminated the claim in 2023 following an updated eligibility review.

Did a state anti-discretion statute strip Aetna of deferential review?

The threshold dispute was the ERISA standard of review. The plan gave Aetna discretionary authority to determine eligibility, which ordinarily triggers abuse-of-discretion review. Plaintiff argued that a 2019 Maine statute, Me. Stat. § 2847-V, which bars group health and disability policies from reserving sole or absolute discretion to the insurer, displaced that clause and required de novo review. The court disagreed. It read the statute to reach only policies issued, continued, or renewed after the statute took effect, and found that the plan here was issued in 2014 with a claim arising in 2016. The court rejected the argument that Aetna’s continued payment of benefits after 2019 amounted to continuing or renewing the policy, reasoning that paying an existing claim is a legal obligation rather than a volitional renewal. The absolute-discretion clause therefore remained enforceable, and the court reviewed Aetna’s decision for substantial evidence.

Does paying benefits for years shift the burden onto the insurer?

Plaintiff argued that because Aetna had approved and paid the claim for seven years, the burden should shift to Aetna to prove her condition had improved. The court rejected that framing. Under the plan language, the burden to prove continued disability remained with Plaintiff at all times. A prior grant of benefits, the court explained, does not operate as an estoppel that prevents an insurer from ever reconsidering, and an insurer may discontinue benefits when new information calls the earlier finding into question. The court distinguished cases where an insurer terminates benefits based on the same record that supported the initial award, finding instead that the information before Aetna in 2023 differed materially from what it had in 2016. On that basis, the court gave the prior payment history only limited weight.

How did the court weigh Aetna’s conflict of interest and the Social Security award?

The court acknowledged that Aetna operated under a structural conflict as both the entity that evaluates and the entity that pays claims, and that Aetna did not appear to have taken specific steps to insulate its decision from that conflict. But because Plaintiff had not shown how the conflict actually affected the claims decision, the court gave it only some weight. The court likewise gave some weight to the SSA’s 2018 finding of disability, while noting that the determination was several years old, had not been revisited, and predated the evidence Aetna developed in 2023.

Was the termination supported by substantial evidence?

The court analyzed the physical and cognitive components of the claim separately. On the physical condition, it found substantial evidence that Plaintiff’s Cyclic Vomiting Syndrome episodes had become less frequent between 2016 and 2023, drawing on treating-provider notes, an independent medical examination, surveillance, and three record reviews by board-certified physicians. On cognition, the court noted that Plaintiff’s neuropsychological evaluations dated to 2016, 2017, and 2020, that Aetna had put Plaintiff on notice it could not evaluate cognitive conditions without supporting records, and that Plaintiff did not obtain an updated evaluation. Aetna’s reviewing physicians concluded that the record lacked current clinical findings of disabling cognitive impairment. Applying the deferential substantial-evidence standard, the court held that Aetna’s conclusion was one a reasonable mind could accept, and that Aetna had the discretion to credit its reviewing physicians over Plaintiff’s treating providers so long as it did not arbitrarily refuse to consider reliable evidence. The court granted Aetna’s motion, denied Plaintiff’s, and dismissed the complaint with prejudice.