McIntyre v. Reliance Standard Life Insurance Company

Background

Melissa A. McIntyre brought a claim under the Employee Retirement Income Security Act (ERISA) against Reliance Standard Life Insurance Company for denial of long-term disability benefits. McIntyre worked as a registered nurse at Mayo Clinic Health System beginning in December 2003. She had Charcot-Marie-Tooth Syndrome, a neurological condition affecting peripheral nerves that can cause loss of sensation and muscle atrophy.

McIntyre stopped working in July 2011 because she had difficulty balancing, walking to patient rooms, and managing fatigue that required frequent naps. Reliance approved her long-term disability benefits beginning October 18, 2011. The plan provided benefits under a “Regular Occupation” definition for the first 24 months and then under an “Any Occupation” definition. Under the latter definition, the claimant had to be unable to perform the duties of any occupation because of disability.

In February 2016, Reliance notified McIntyre that it considered her capable of sedentary and light work and would not continue her Any Occupation benefits after December 1, 2015. McIntyre appealed through her attorney and submitted opinions and reports from her treating neurologist, a rehabilitation consultant, herself, and other witnesses. Reliance later required an independent medical examination, which ultimately concluded that McIntyre could perform full-time sedentary work. Reliance upheld its termination decision on December 21, 2016.

Standard of Review

The court determined that it would review Reliance’s decision de novo, meaning it would evaluate the benefit claim independently rather than defer to Reliance’s decision. The court found both a conflict of interest and serious procedural irregularities.

Reliance both decided eligibility for benefits and paid the benefits, creating a conflict of interest. The court also found that Reliance took 204 days to decide McIntyre’s appeal, even though the applicable rule generally required a decision within 45 days. The court determined that only 34 days of the delay could be excluded while Reliance sought additional medical records. It found that the independent-medical-examination period did not properly extend the deadline because the examination process was within Reliance’s control and the delays were not attributable to McIntyre.

The court further found that these problems were connected to the benefit decision and that Reliance’s handling of the evidence raised serious doubts about whether its decision was arbitrary. In particular, Reliance’s denial letter focused primarily on the independent medical examination and gave insufficient attention to contrary opinions from McIntyre’s treating neurologist, rehabilitation consultant, Reliance employees, family members, friends, and McIntyre herself. The court concluded that these circumstances showed a breach of Reliance’s fiduciary duty, meaning a failure to act properly in administering the plan for the claimant.

Merits of the Benefits Claim

After independently reviewing the administrative record, the court found that McIntyre was totally disabled under the plan’s Any Occupation definition. It concluded that she could not perform all material duties of any occupation on a full-time basis.

The court relied on evidence that McIntyre’s condition had progressed, that she could not perform tasks for more than about 30 minutes because of fatigue and pain, and that her rehabilitation consultant found she could perform certain activities only on an isolated basis rather than continuously as full-time work requires. The court also found that surveillance of McIntyre was consistent with her reported limitations: she walked with a noticeable limp, worked outside for only brief periods, and generally did not leave home after about 2 or 3 p.m.

The court found that the independent medical examiner’s opinion was not enough to support ending benefits. Although the examiner concluded that McIntyre could work full time in a sedentary position, the report did not explain how her documented pain, fatigue, and concentration problems would affect that work. The court also reasoned that frequent breaks and naps would reduce the time McIntyre could actually work below a full-time schedule.

Disposition

Judge John R. Tunheim granted McIntyre’s motion for summary judgment and denied Reliance’s motion for summary judgment. The court held that McIntyre qualified for disability benefits under the plan’s Any Occupation benefit.