Quigley v. Unum Life Insurance Company of America

Background

James Quigley sued Unum Life Insurance Company of America under the Employee Retirement Income Security Act of 1974, or ERISA, seeking long-term disability benefits, a waiver of life-insurance premiums, related declaratory relief, and attorney’s fees and costs. Quigley worked for more than twenty-three years in TP ICAP Americas Holdings, Inc.’s bond trading department. After a September 2016 car accident, he reported headaches, cognitive problems, visual difficulties, dizziness, and other symptoms. He continued working until taking medical leave on November 2, 2020.

Quigley submitted claims to Unum for short-term disability, long-term disability, and life-insurance premium benefits. Unum denied the long-term disability and premium-waiver claims in 2021 and upheld those denials on appeal in April 2022. Quigley and Unum then filed cross-motions for summary judgment, asking the court to decide the case without a trial because they contended that no important facts were genuinely disputed.

Standard of Review

The court held that it would review Unum’s benefits decision independently, rather than defer to Unum’s interpretation of the plans. Unum had twice stated in its answer that it did not dispute independent review, and the court denied Unum’s request to amend its answer to change that position. The court found that changing the position would prejudice Quigley because he had relied on Unum’s earlier statements in developing his litigation strategy.

Under independent review, the court would interpret the plans, assess the medical evidence, and decide whether Quigley proved by more than a 50-percent likelihood that he qualified for benefits. But the court emphasized that summary judgment was unavailable if the record contained a genuine dispute over an important fact.

Disputes Preventing Summary Judgment

The court identified a dispute about the occupation against which Quigley’s disability had to be measured. Unum characterized his occupation as “Bond Department Manager,” while Quigley described his role as Senior Bond Broker and Trading Desk Manager. The parties disagreed about whether executing trades was a material part of his job and about the cognitive, audiovisual, concentration, and sustained-work demands of that occupation in the national economy.

The court also found conflicting evidence about whether Quigley was disabled under the plans. Quigley’s treating providers and other professionals offered opinions that his symptoms and cognitive impairments prevented him from performing his occupation. Unum’s medical reviewers reached opposing conclusions, including that the medical evidence did not establish disabling functional limitations and that some testing results had validity concerns.

Additional factual disputes concerned the significance of Quigley’s treatment history, the amount of objective medical evidence supporting his reported symptoms, the fact that he continued working for several years after the accident, and the relative weight given to opinions from treating providers and doctors who reviewed records without examining him. The court also clarified that the plan required Quigley to show that he was unable to perform the material and substantial duties of his occupation; showing only that those duties were difficult was not enough. Whether Quigley met that standard remained a question for the factfinder.

The court declined to consider the Social Security Administration’s later finding that Quigley was disabled beginning November 2, 2020. The finding occurred after Unum completed its review, and the materials submitted to the court did not explain the basis for the Social Security Administration’s decision.

Full and Fair Review

Quigley alternatively argued that Unum had not given him the full and fair review required by ERISA regulations because a medical professional had not reviewed every supplemental document he submitted during the appeal. The court rejected that argument. Unum had consulted health care professionals, including Dr. Jacqueline Crawford and Dr. Peter Brown, and Dr. Crawford reviewed an earlier set of supplemental materials and prepared an addendum. The court held that the regulations did not require a medical professional to address every document in detail and that a claimant could not keep an appeal open indefinitely by submitting documents in successive batches. The court therefore concluded that Quigley received a full and fair review.

Disposition

The court denied Quigley’s motion for summary judgment and denied Unum’s cross-motion for summary judgment because genuine disputes of material fact remained. The court also denied Unum’s motion to strike Quigley’s factual statement, explaining that such motions are generally disfavored and that the court could simply disregard improper arguments or legal conclusions. The parties were ordered to submit a joint status letter addressing how they proposed to proceed, including whether they would consent to a trial based on the papers.