Darden v. Anthem Blue Cross Life and Health Insurance Company Plan)/Elevance…

Background

Michael Darden received long-term disability benefits from Anthem beginning August 2, 2021. On July 27, 2023, Anthem administratively closed his claim because the plan limited benefits for mental illnesses to 24 months and Anthem determined that Darden was not physically disabled. Darden was later approved for Social Security disability benefits, and Anthem upheld the claim closure on administrative appeal.

Darden sued Anthem under the Employee Retirement Income Security Act of 1974 (ERISA), bringing one claim under 29 U.S.C. § 1132(a)(1)(B). He sought a declaration that Anthem had violated the plan, that he was entitled to monthly benefits through July 2033, and that Anthem could not recover an overpayment allegedly caused by its errors. He also sought monthly benefits with interest from July 2023 through the date of judgment.

After the lawsuit was filed, Anthem re-reviewed Darden’s claim and approved it retroactively to July 21, 2023. Anthem paid retroactive benefits and said continuing monthly benefits were approved subject to periodic medical updates. At the same time, Anthem offset $53,250 from the benefits it otherwise would have paid, estimating that amount from Darden’s Social Security disability benefits. Anthem later notified Darden that, after revising its calculations, it considered him overpaid by $28,150.40.

Motions and Legal Standard

The parties filed cross-motions for judgment under Federal Rule of Civil Procedure 52. Under that rule, the court makes factual findings and separate legal conclusions in a case tried without a jury. In this ERISA proceeding, the court evaluated the record and the persuasiveness of the parties’ positions. The opinion states that Anthem had not filed an administrative record, so the court primarily cited documents attached to Darden’s motion.

Court’s Analysis

The court held that Darden’s claim was not moot. Although Anthem had paid some retroactive benefits and approved benefits going forward, Darden continued to dispute whether Anthem could offset his benefits based on Social Security disability benefits and whether Anthem could require him to repay money. The court therefore found a live dispute over whether Darden was entitled to additional benefits or owed money to Anthem.

The court remanded Darden’s claim to Anthem to resolve the offset dispute in the first instance. It explained that the record contained minimal evidence about how the offsets were calculated, making it inappropriate for the court to decide as a matter of law whether the offsets were allowed and correctly calculated. Anthem had agreed in its briefing that remand would be appropriate if the case was not dismissed, although it argued at the hearing that remand could be administratively difficult.

The court also addressed Darden’s requests for equitable relief, including repayment of the offset benefits, an injunction, additional monetary relief for financial harm, transfer of his claim to a different affiliated company, and referral to the Department of Labor’s Employee Benefits Security Administration. The court held that it could not order that relief because Darden’s complaint asserted only a claim under § 1132(a)(1)(B), not a claim under § 1132(a)(3), which authorizes appropriate equitable relief. The opinion does not state that the court separately entered a judgment denying each requested form of equitable relief; it states that the relief could not be ordered in this case.

Disposition

Judge Rita F. Lin granted Darden’s motion for judgment and denied Anthem’s motion for judgment. The court remanded Darden’s claim to Anthem for further proceedings concerning the validity and calculation of offsets based on his Social Security disability benefits. The court also stated that any party believing it prevailed could file a bill of costs within 14 days.