Why a Treating Doctor’s Support Letter Wasn’t Enough: N.D. California Upholds Reliance Standard’s ERISA Disability Termination

In Bachand v. Reliance Standard Life Insurance Company, No. 25-cv-02061-MMC, 2026 WL 2723471 (N.D. Cal. Sept. 15, 2026), Judge Maxine M. Chesney of the United States District Court for the Northern District of California denied Plaintiff’s motion for judgment and granted Reliance Standard’s motion for judgment under Federal Rule of Civil Procedure 52, upholding the termination of long-term disability benefits under an ERISA-governed group plan. Reviewing the claim de novo, the court held that Plaintiff did not prove by a preponderance of the evidence that she remained totally disabled at the time Reliance terminated her benefits. For anyone navigating a group disability claim, the decision is a detailed study in how courts weigh a treating doctor’s contemporaneous records against a later opinion letter written to support the claim.

What did Plaintiff have to prove under the ERISA plan?

Plaintiff worked as a Research and Development Engineer for Medtronic, a role a vocational specialist classified as sedentary. In February 2022, at age 27, she was hospitalized and diagnosed with acute autoimmune hepatitis and began taking prednisone, a steroid. Over the following year she treated with a hepatologist, Dr. Holt, and an immunologist, Dr. Ahn, who worked to taper her off prednisone and onto the immunosuppressant Myfortic because of the health risks of long-term steroid use. After a period of returning to and stopping work, she initiated her claim, and Reliance approved long-term disability benefits in July 2023 following a May 2023 flare marked by elevated liver enzymes, a rash, excessive fatigue, and abdominal pain.

Because Plaintiff had received benefits for more than twelve months, the Policy no longer measured disability against her own job. It required her to show she was totally disabled from “Any Occupation,” meaning an occupation normally performed in the national economy for which she was reasonably suited by education, training, or experience. The parties stipulated to de novo review, so the court gave no deference to Reliance and Plaintiff carried the burden of proving disability by a preponderance of the evidence. The court emphasized that a diagnosis alone does not establish disability; even a serious, chronic, lifelong condition is not disabling unless the record shows it actually prevents the claimant from working.

Why did the treating physician’s opinion fail to carry Plaintiff’s burden?

Dr. Ahn submitted a letter and later a questionnaire concluding that Plaintiff’s chronic symptoms, despite stable liver function, severely limited her ability to work and capped her at roughly twenty hours per week. The court found those conclusions inconsistent with Dr. Ahn’s own contemporaneous clinical summaries. His treatment notes showed that after the May 2023 flare, Plaintiff steadily improved. By November 2023 her liver enzymes were stable and her doctors resumed tapering prednisone; by January 2024 Dr. Ahn recorded she was “doing well, finally off prednisone,” and Dr. Holt noted she “reports feeling well.” For the roughly thirteen months preceding his August 2024 summary, the strongest descriptor in the notes was “some fatigue and muscle aches.”

The court drew a sharp line between what Dr. Ahn wrote in his support letter and what his records documented. Many symptoms he cited as disabling, including dizziness, headaches, racing heartbeat, shortness of breath, and difficulty recovering from exertion, appeared nowhere in his treatment notes. His claim of disabling tinnitus traced to a single “loud noise incident” at a concert, and an audiogram showed only a four percent hearing reduction in one ear, which Plaintiff managed with custom headphones. In the court’s view, the letter described a far more impaired patient than the chart the doctor had been keeping all along. The court applied the settled ERISA rule that a plan need not give special weight to a treating physician and may discount a treating doctor’s conclusions where they are not supported by that doctor’s own contemporaneous examinations.

Two further points weighed against the opinion. Dr. Ahn recommended part-time work “for at least six months” but estimated Plaintiff could work twenty hours per week, which under the Policy’s definitions is itself full-time work, though the court did not rest its decision on that point because Reliance had not relied on it. And Dr. Ahn did not return four calls from Reliance’s reviewing physician, Dr. Jackson, who left voicemails asking to discuss the basis for his conclusions. The court treated that silence as supporting Reliance’s decision to discount the opinion, reasoning that a doctor willing to write a letter but unwilling to answer questions about it from another physician gives the administrator reason to doubt the letter.

How did the court treat Plaintiff’s own testimony about her symptoms?

The court acknowledged that a claimant’s subjective statements can, on their own, support a finding of total disability. It found, however, that Plaintiff’s personal statement failed for the same reason as Dr. Ahn’s opinions: her medical records for the relevant period did not reflect her reporting, or any physician recording, symptoms severe enough to prevent suitable work. The court noted that Reliance was not required to accept her reported symptoms at face value and could take the absence of supporting objective evidence into account. It also observed that Plaintiff visited Dr. Ahn far less often in the thirteen months before her benefits ended (four visits) than in the earlier flare period (eleven visits), and that two of those later visits clustered around the filing of her appeal.

What did the court decide about supplementing the administrative record?

In a ruling that went Plaintiff’s way, the court agreed to consider two of Dr. Ahn’s clinical summaries that were not in the administrative record. Although a court ordinarily tries an ERISA case on the record the administrator had, it may supplement that record when necessary for an adequate de novo review. Here, Reliance had asked Plaintiff to authorize the release of updated records but then never requested the corresponding summaries from Dr. Ahn, leaving a gap the court found it needed to fill in order to weigh Dr. Ahn’s later letter and questionnaire. The court admitted the June and August 2024 summaries, which predated the appeal deadline, but declined to admit a later October summary. Notably, the supplemented records ultimately cut against Plaintiff, because they too documented improvement rather than disabling severity.

What does the decision say about the plan’s obligations?

The court confirmed that Reliance was not required to order an independent medical examination and was not required to give special weight to Plaintiff’s treating physicians. It also held that Reliance’s brief explanation, though “by no means an exemplar for others to follow,” satisfied ERISA’s requirement of a specific reason for denial, because it told Plaintiff her records did not support total disability. The court treated the administrator’s adoption of Dr. Jackson’s opinion as an implicit rejection of the contrary statements by Plaintiff and Dr. Ahn.

What is the takeaway for group disability claimants?

The court expressed genuine sympathy for Plaintiff and the lifelong nature of her condition, but held it was constrained by the record before it. The decision underscores a recurring theme in ERISA long-term disability litigation: contemporaneous treatment notes carry more weight than opinion letters prepared after benefits are terminated. When a supportive letter reaches for symptoms and limitations the treatment record never documented, the gap tends to sink the claim rather than save it, and the treating physician’s willingness to engage with the plan’s reviewer can matter as much as the words in the letter.