Bachand v. Reliance Standard Life Insurance Company

Background

Anna C. Bachand worked for Medtronic, Inc. as a Research and Development Engineer, an occupation classified as sedentary. Through her employer, she participated in a group disability insurance policy issued by Reliance Standard Life Insurance Company. The policy provided long-term disability benefits to participants who met the policy’s definition of disability.

Bachand was hospitalized in February 2022 and diagnosed with acute autoimmune hepatitis. She later stopped working, submitted a claim for long-term disability benefits, and received benefits from Reliance beginning in August 2022. Reliance later determined that Bachand was capable of at least sedentary work because she had stopped taking prednisone, was stable while taking Myfortic, and had stabilizing liver function. Reliance stopped the benefits and denied Bachand’s appeal.

Bachand argued that ongoing fatigue, muscle aches, tinnitus, headaches, and other symptoms—including symptoms she attributed to her condition and medications—prevented her from working full time. Her doctor, Sam Ahn, wrote that her symptoms severely affected her ability to perform essential work functions and later stated that she could work 20 hours per week. Bachand also submitted a personal statement describing her symptoms. Reliance relied on the review of Christian Jackson, M.D., who concluded that the medical information did not support work restrictions or limitations.

Bachand filed this action under the Employee Retirement Income Security Act, a federal law governing many employee benefit plans, seeking unpaid long-term disability benefits, interest, attorney’s fees, and costs.

Review of the Administrative Record

The court reviewed Reliance’s benefit decision independently, without deferring to Reliance’s conclusions. The court explained that Bachand had the burden to prove, by the greater weight of the evidence, that she was disabled under the policy.

The court allowed consideration of clinical summaries from Bachand’s June 4 and August 13, 2024 visits with Dr. Ahn. It reasoned that those records were needed to evaluate the weight of Dr. Ahn’s later letter and questionnaire and to assess Bachand’s reported symptoms. The court did not identify the October 31, 2024 clinical summary among the records it would consider.

Policy Definition and Merits

Under the policy, after benefits had been paid for 12 months, “Totally Disabled” meant that an employee could not perform the material duties of any occupation because the employee could perform those duties only part time or could perform only part of them full time. “Any Occupation” meant an occupation normally performed in the national economy for which the employee was reasonably suited based on education, training, or experience.

The court concluded that Bachand did not prove that her illness prevented her from performing the material duties of any suitable occupation when Reliance denied further benefits. The court noted that a medical diagnosis alone does not establish disability.

The court found that Reliance had provided a specific reason for its decision: the medical records did not support restrictions and limitations establishing total disability. The court treated Reliance’s rejection of Bachand’s and Dr. Ahn’s statements as implicit in that explanation.

The court determined that Dr. Ahn’s opinions were not adequately supported by his contemporaneous treatment notes. Those notes described Bachand as improving, reported some fatigue and muscle aches, or stated that she was doing well or feeling well. The court also found that the treatment notes did not support disabling levels of tinnitus, sound sensitivity, dizziness, headaches, racing heartbeat, shortness of breath, difficulty recovering from exertion, or abdominal discomfort. The court further observed that Dr. Ahn did not return Dr. Jackson’s repeated telephone calls seeking to discuss the basis for his opinions.

The court also found Bachand’s personal statement insufficient. Although a claimant’s statements about symptoms can support a disability finding, the court concluded that Bachand’s statement was not supported by contemporaneous medical records showing that her symptoms were severe enough to prevent suitable work.

The court distinguished Bachand’s former job from the policy’s broader definition of disability. Because the policy required her to show that she could not perform any suitable occupation after the initial benefit period, the court considered evidence that a biomedical engineer position was sedentary and generally required sitting, with only occasional lifting of up to 10 pounds and brief periods of walking or standing. The court found that the evidence did not establish that Bachand could not perform such work.

Disposition

The court found that Reliance’s decision to terminate Bachand’s long-term disability benefits was supported by the record. It denied plaintiff’s motion for judgment and granted defendant’s motion for judgment. The order states that it constitutes the court’s findings of fact and conclusions of law.