In Ryan v. Hartford Life and Accident Insurance Company, the Wisconsin court found that Hartford's termination of long-term disability (LTD) benefits was unreasonable because it failed to assess Dr. Ryan’s cognitive limitations in relation to the specific demands of her occupation as an internal medicine physician.
Key Takeaways:
- Insurers Must Consider Specific Job Duties: Under an “own occupation” definition of disability, insurers cannot simply rely on general cognitive testing; rather, they must evaluate whether the person can perform the actual, essential duties of their specific profession.
- Contextual Review Is Required: Medical opinions by an insurance company’s doctor must be interpreted in the context of the claimant’s past performance and the physical and cognitive demands of their occupation, especially in high-skill fields like medicine.
- Conflicting Expert Opinions Require Reasoned Analysis: Courts will not rubber-stamp a denial based on selective opinions by paid consultants, especially when those “experts” fail to address material vocational or functional job duties.
- SSDI Awards Cannot Be Dismissed Lightly: While not binding, a Social Security disability award, particularly when based on a stricter definition of disability, must be meaningfully considered by insurers. This is especially true when the disability insurance company requires a claimant to apply for SSDI.
Case Background
Frances Ryan, M.D., a highly experienced internal medicine physician, suffered a traumatic brain injury from a fall in March 2018. Her symptoms included dizziness, migraines, memory loss, and difficulty concentrating. Initially, Hartford approved her LTD claim under a policy that defines “disabled” as being unable to perform one or more of the “Essential Duties” of one’s occupation.
However, Hartford later terminated Dr. Ryan’s benefits, concluding she had no cognitive limitations that would prevent her from working as a physician. Hartford relied heavily on general cognitive test results showing “mostly intact” functioning without weighing whether Ryan could still meet the specific cognitive demands of internal medicine practice.
Legal Analysis: Arbitrary and Capricious Review
Under ERISA, courts reviewing LTD denials apply an arbitrary and capricious standard when the insurer has discretionary authority to interpret policy terms, like Hartford did here. Despite the deferential standard, the court emphasized that benefits decisions must be “supported by record evidence” and must consider whether the claimant can perform their job duties, not just exhibit general cognitive functionality.
The court found Hartford’s review lacking for several reasons:
- Failure to Evaluate Occupational Demands: Hartford did not analyze whether Ryan’s cognitive deficits, including reduced abstract thinking and problem-solving ability, would prevent her from safely and effectively performing the complex tasks required of an internal medicine physician, such as differential diagnosis and supervision of clinical staff.
- Selective Use of Medical Evidence: While Hartford’s consultants concluded Ryan was not “globally impaired,” they failed to contextualize their assessments within her high-functioning, pre-injury baseline, or the demands of her specific occupation. Notably, Hartford disregarded critical findings from neuropsychologist Dr. Stephen Rothke, who opined that Ryan’s impairments would likely compromise patient safety due to reduced endurance and decision-making capacity.
- Dismissal of SSA Disability Finding: Although Hartford acknowledged that Ryan was awarded SSDI benefits, it dismissed the relevance of that determination without adequate explanation. This is especially true given the SSA’s definition of disability is more stringent than Hartford’s “own occupation” standard. Courts have consistently criticized insurers for ignoring an award of SSDI as proof of disability, especially when the claimant is required to apply for SSDI as a condition of their policy.
Why This Decision Matters for Disability Claimants
This case sends a strong message to insurers: A cookie-cutter approach to disability reviews, especially for high-functioning professionals with an own occupation definition of disability, will not survive judicial scrutiny. Claimants with complex cognitive conditions often fall victim to overly broad interpretations of “functional capacity” that ignore the nuanced mental demands of their specific professions, or any profession.
The court’s ruling also underscores the importance of thorough vocational analysis in ERISA litigation. The court highlighted expert testimony from a vocational specialist who detailed the abstract, analytical, and supervisory duties required by internal medicine doctors. By failing to engage with this evidence, Hartford violated the very terms of its own policy and called into question the legitimacy of its benefit termination.
Help from a Lawyer with Expertise in Disability Insurance
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Disclaimer: Dabdoub Law Firm did not handle this case.