Lucas v. Hartford Life and Accident Insurance Company

Background

Suzanne Lucas brought an Employee Retirement Income Security Act (ERISA) action challenging Hartford Life and Accident Insurance Company’s termination of her long-term disability benefits. Hartford began providing benefits in 2021 after Lucas claimed a chronic disability prevented her from working.

In January 2024, Hartford required Lucas to attend an independent medical examination. Lucas attended but refused to allow the examiner to copy her photo identification, refused to sign certain paperwork, and left before the examination was completed. Hartford then notified her that it was terminating her benefits because it could not determine whether she remained eligible based on the incomplete information.

The termination letter told Lucas that she could appeal within 180 days and directed her to send the appeal to a post-office box in Kentucky. Lucas’s counsel communicated with Hartford employees about the claim. Hartford employees told counsel that the next step was to submit a formal appeal. Lucas alleged that she appealed by letter dated August 20, 2024. Hartford maintained that it did not receive or know about the appeal until after the case began, when Lucas’s counsel disclosed that the appeal had been sent by email to a Hartford claims specialist rather than by mail to the address in the termination letter.

After Hartford located the email, it proposed staying the case and sending Lucas’s claim back to Hartford for review. Lucas declined. Hartford then asked for leave to move for a stay and remand or, alternatively, for summary judgment based on failure to exhaust administrative remedies.

Remand request

The court explained that remand—sending a claim back to the insurer for further consideration—is often used after a court finds that an ERISA benefits decision was legally improper, particularly when the case involves procedural problems in the insurer’s review. The court had not yet reviewed Hartford’s benefits decision, however. It also noted that Lucas had declined Hartford’s proposed remand and opposed the court’s authority to order one at this stage.

The court therefore denied in part Hartford’s motion to the extent it sought to remand Lucas’s claim to Hartford. The court stated that remand would not be ordered at that time.

Exhaustion and further motion practice

The court explained that administrative exhaustion is a threshold requirement generally requiring an ERISA claimant to pursue the plan’s claim procedure before filing suit. The court did not decide whether Lucas satisfied that requirement. It stated that, even if Hartford’s failure to decide the appeal within the regulatory period meant that Lucas’s administrative remedies were treated as exhausted, that would allow her to bring the lawsuit but would not necessarily prevent a later remand if she prevailed on the merits.

The court granted in part Hartford’s motion to the extent it sought leave to file a motion for summary judgment on whether Lucas exhausted her administrative remedies. If that motion is denied and Lucas is found to have exhausted her remedies, the case will proceed to a bench trial on the merits. The court directed the parties to propose a briefing schedule and address whether additional discovery is needed before the exhaustion motion is briefed. The Clerk was directed to terminate the motion at Docket 30.

Ruling

Judge Valerie Caproni denied in part Hartford’s motion to remand Lucas’s claim and granted in part Hartford’s motion for leave to seek summary judgment on exhaustion. The opinion did not decide exhaustion, the validity of Hartford’s benefits termination, or the merits of Lucas’s ERISA claim.