Mackey v. Life Insurance Company of North America
- Alvin Hellerstein
- 1:22-cv-07072
- U.S. District Court · Southern District of New York
- 3
Mackey v. New York Life, Judge Hellerstein denied New York Life’s motion to dismiss Mackey’s disability-benefits claim under federal employee-benefits law.
Ryan Mackey’s claim for long-term disability benefits against New York Life Insurance Company was allowed to proceed past the motion-to-dismiss stage; the court did not decide whether he was ultimately entitled to benefits.
What happened
In Mackey v. Life Insurance Company of North America, Ryan Mackey challenged the denial of long-term disability benefits under an employee benefit plan governed by federal law. He sought $92,215.50 in benefits, plus attorney fees and costs, from New York Life Insurance Company as successor to Life Insurance Company of North America.
New York Life asked the court to dismiss the amended complaint, arguing that Life Insurance Company of North America—not New York Life—issued the disability policy. New York Life also argued that Mackey had not alleged enough facts showing New York Life could be responsible for paying the benefits.
Judge Alvin K. Hellerstein denied the motion. The court held that Mackey’s allegations that New York Life administered his claim, reviewed his appeal, made the final decision, and refused to pay benefits were sufficient to support a plausible claim. The court set an initial case-management conference for February 24, 2023.
The detailed version
- Mackey v. Life Insurance Company of North America · No. 1:22-cv-07072
- Alvin Hellerstein
- Jan. 31, 2023
Background
Ryan Mackey sued New York Life Insurance Company, identified in the amended complaint as successor in interest to Life Insurance Company of North America (LINA). The dispute concerns long-term disability benefits under an employee benefit plan governed by the Employee Retirement Income Security Act, a federal law commonly called ERISA. Mackey alleged that he stopped working in June 2020 because of multiple medical conditions and that New York Life wrongfully denied benefits. He sought $92,215.50 in benefit payments, along with attorney fees and costs.
The parties did not dispute that LINA issued the group disability policy. Mackey attached the LINA policy to his amended complaint. He alleged, however, that after New York Life acquired Cigna’s group insurance business in December 2020, New York Life controlled the benefit-decision process for the plan, including his claim. Specifically, he alleged that New York Life administered his disability claim, reviewed the evidence submitted on appeal, made the final claim decision, upheld the denial of his appeal on April 12, 2022, and refused to pay benefits on the ground that he did not meet the plan’s definition of disability.
Motion to Dismiss
New York Life moved to dismiss the amended complaint under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. New York Life argued that the policy was issued by LINA rather than New York Life and that Mackey’s allegations about New York Life’s responsibility were too thin to support a reasonable conclusion that New York Life could be liable for the benefits payable by LINA.
Court’s Analysis and Ruling
The court was required at this stage to accept the complaint’s factual allegations as true and draw reasonable inferences in Mackey’s favor. The court concluded that the allegations describing New York Life’s role as the plan’s decision-maker, if true, were sufficient to state a claim that was plausible on its face. The court therefore denied New York Life’s motion to dismiss.
The court noted that discovery could show that New York Life played no significant role in administering Mackey’s claims. If so, the court said the case could later be suitable for summary judgment in New York Life’s favor, with costs awarded. The Clerk was directed to terminate the motion, and the parties were ordered to appear for an initial case-management conference on February 24, 2023.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.