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This month’s Friday Five highlights recent court decisions interpreting the ERISA long-term disability “any occupation” standard, with practical takeaways for claim administrators and litigators. We also examine current discovery disputes in benefits litigation, including scope, proportionality, and strategy considerations for building or defending the administrative record.
The Saul Ewing ERISA Litigation Team
- The U.S. District Court for the Northern District of Illinois applied ERISA’s “any occupation” standard in Plaintiff Tiffany Scorzo’s suit against Defendant Unum Life Insurance Company of America challenging the termination of her long-term disability benefits under her employer, Starbucks’s, Long-Term Disability plan. The plan required proof that Plaintiff could not perform any gainful occupation for which she was reasonably fitted by education, training, or experience. The parties agreed the case would be decided on the administrative record under Federal Rule of Civil Procedure 52(a) and that the court would review the benefits determination de novo because the plan did not confer discretionary authority on Defendant. Although Plaintiff, who was diagnosed with multiple sclerosis, was initially approved for benefits, Defendant later discontinued them after concluding Plaintiff was not precluded from performing other gainful sedentary occupations. The court held that Plaintiff failed to prove, by a preponderance of the evidence, that she was unable to perform the duties of any gainful occupation. The Court emphasized that evidence of symptoms, without corresponding functional limitations, was insufficient to meet that burden. The court also noted that the denial of Plaintiff’s Social Security Disability Insurance claim weighed against her request for continued benefits. Accordingly, the court denied Plaintiff’s motion for judgment and granted Defendant’s cross-motion. Scorzo v. Unum Life Insurance Company of America, No. 23-cv-3836, 2026 WL 2070002 (N.D. Illinois, July 17, 2026).
- The U.S. District Court for the Central District of California held a bench trial on the administrative record and, applying de novo review, considered whether Defendant, Reliance Standard Life Insurance Company, properly denied Plaintiff, Laura Cyr’s, claim for LTD benefits under the policy it issued to her former employer, Channel Technologies, Inc. Plaintiff was employed until 2000, and the employer had an ERISA-governed plan providing LTD benefits through a policy issued by Defendant. The plan required proof of total disability, defined as the inability to perform material duties of one’s regular occupation due to injury or sickness. Plaintiff worked as Vice President of Administration, and her duties included managing departments, formulating plans, and directing accounting and budget functions. Plaintiff left employment in 2000 and her disability claim was granted in 2001 based on a back condition stemming from a previous automobile accident. Defendant terminated Plaintiff’s benefits in 2021 finding that Plaintiff no longer met the definition of total disability. The Court determined that Plaintiff had met her burden to prove by a preponderance of the evidence that she was disabled under the plan’s terms and entitled to LTD benefits. In reaching this decision the court gave greater weight to the opinions of Plaintiff’s treating physicians, who had conducted in-person evaluations, over the doctors who performed paper reviews on behalf of Defendants. The court noted that Defendant and its doctors failed to fully apply the standard of disability in the policy by assessing Plaintiff’s capacity to perform only the duties of a sedentary job rather than her specific duties, including non-physical duties. Cyr v. Reliance Standard Life Insurance Company, No. 2:23-cv-06286-DSF-RAO, 2026 WL 2056667 (C.D. Cal. July 15, 2026).
- The U.S. Southern District of New York denied an ERISA long-term disability motion to compel discovery into matters outside the administrative record. Plaintiff, Dominic De Mello, filed a motion to compel discovery from Defendant, First Unum Life Insurance Company, regarding the denial of his LTD benefits. Plaintiff worked for employer, Schulte Roth & Zabel LLP, and participated in employer’s welfare benefit plan when he applied for LTD benefits after contracting COVID-19 and being diagnosed with long COVID. The claim was denied based on the file reviews by three doctors. Plaintiff filed suit under Section 502(a)(1)(B) of ERISA, alleging that the denial of his benefits violated the terms of the plan and his rights. The court noted that the party seeking to compel discovery must show relevance and that discovery must be proportional to the needs of the case. The court concluded that Plaintiff had not demonstrated how his requests were relevant or proportional to the needs of the case. Plaintiff's motion was based on the assertion that Defendant operated under a conflict of interest because it both reviews and pays claims under the plan. However, the court held that a conflict of interest does not per se constitute good cause to consider evidence outside of the administrative record. A conflict can rise to the level of good cause only when bolstered by specific allegations of an additional factor, such as a lack of established criteria for deciding appeals or a failure to maintain written claim review procedures. De Mello v. First Unum Life Insurance Company, No. 25-cv-7933 (LJL), 2026 WL 2032059 (S.D.N.Y. July 14, 2026).
- The U.S. District Court for the Eastern District of Michigan reiterated that discovery is generally unavailable in ERISA cases because judicial review is ordinarily limited to the administrative record, subject to a narrow exception for evidence supporting a procedural challenge. Nicole C. Strong was an hourly employee of Ford Motor Company at the time of her death, and, through her employment, obtained group benefits that included two Accidental Death and Dismemberment policies underwritten by Defendant Metropolitan Life Insurance Company. Strong’s death certificate listed the cause of death as an accident resulting from Diphenhydramine (Benadryl) toxicity. Plaintiff, Strong’s husband, made a claim under these policies that Defendant denied finding that Strong voluntarily ingested a lethal dose of Benadryl triggering a policy exclusion barring coverage for loss resulting from the voluntary ingestion of medication other than as prescribed. Defendant maintains that Plaintiff’s claim should be dismissed because he failed to exhaust all administrative remedies as set forth in the Plan Description. Federal law permits an individual covered under an ERISA plan “to recover benefits due to him under the terms of his plan, to enforce his rights under the terms of the plan, or to clarify his rights to future benefits under the terms of the plan.” 29 U.S.C. § 1132(a)(1)(B). The court held that dismissal for failure to exhaust was not warranted because the Plaintiff had followed the claims procedure contained in the plan document itself, denied Plaintiff’s request for discovery, and remanded the matter to the Plan Administrator so Plaintiff could pursue an administrative appeal. Strong v. Metropolitan Life Insurance Co., No. 25-12693, 2026 WL 1971254 (E.D. Mich. July 8, 2026).
- The U.S. District Court for the Eastern District of Pennsylvania addressed breach of fiduciary duty and equitable estoppel claims arising out of a challenge to a life insurance policy. Kim DiNicola was employed at employer Vanguard for 21 years and enrolled in group basic life insurance and supplemental life insurance during her employment provided by Defendant Minnesota Life. The group policy totaled $1,656,000 and listed family members as beneficiaries. DiNicola stopped working for her employer in January 2020 and at that time completed a Conversion Application to convert her Group Policy into an Individual Policy for $100,000. Upon DeNicola’s death, Defendant denied Plaintiffs’ claim for the Group Policy's death benefit, claiming that DiNicola only had coverage under the Individual Policy. To establish breach of fiduciary duties, Plaintiffs must establish “(1) the defendant's status as an ERISA fiduciary acting as a fiduciary; (2) a misrepresentation on the part of the defendant; (3) the materiality of that misrepresentation; and (4) detrimental reliance by the plaintiff on the misrepresentation.” Burstein v. Ret. Acct. Plan for Emps. of Allegheny Health Educ. & Rsch. Found., 334 F.3d 365, 384 (3d Cir. 2003). Similarly, to establish equitable estoppel, Plaintiffs must establish “(1) a material representation, (2) reasonable and detrimental reliance upon the representation, and (3) extraordinary circumstances.” Baker v. Pa. Econ. League, Inc. Ret. Income Plan, 811 F. Supp. 2d 1136, 1145 (E.D. Pa. 2011) (citing Curcio v. John Hancock Mut. Life Ins. Co., 33 F.3d 226, 235 (3d Cir. 1994)). Plaintiffs are also required to provide sufficient factual information that permit the plausible inferences they want the Court to draw regarding material misrepresentation and detrimental reliance. The Court found that absent sufficient allegations of a material misrepresentation and reasonable and detrimental reliance, Plaintiffs failed to state a claim against the Defendant for either a breach of their fiduciary duties or equitable estoppel. Fleming v. Minnesota Life Ins. Co., No. CV 23-2558, 2026 WL 2116960 (E.D. Pa. July 22, 2026).
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