Spears v. Liberty Life – Court Dismissed Case Because Claimant Failed to Provide Evidence That the Disability Plan Was False or Misleading

Haley Spears v. Liberty Life Assurance Company of Boston; The Group Life Insurance and Disability Plan of United Technologies Corporation, aka The UTC Choice Integrated Disability Benefit Program

In this case, Haley Spears (“Spears”) was an employee of United Technologies Corporation (“UTC”) where her job was that of an Executive Administrative Assistant. Through her employment with UTC, she was covered by both short- and long-term disability plans. The short-term disability plan was self-insured by UTC, while the long-term disability plan was insured by Liberty Life Assurance Company of Boston (“Liberty”). Under the policy, the term “disabled” for the short-term plan is defined as “unable to perform the material and substantial duties of your current or a similar job for more than 5 consecutive scheduled workdays,” while also providing evidence of your condition from a medical treatment provider. The long-term policy defines the term “disabled” as not being able to do the duties of your “own occupation” for the initial twenty-four months, beyond which you lack the ability to do the duties of “any occupation.”

Spears explained that her job duties included the following:

“[S]end and edit letters, order supplies for two departments, do internet research, organize executive desks and papers, keep a reference guide book updated, change computer settings and fix office equipment on a basic level. She was responsible for communication with the maintenance department. She communicated verbally and by e-mail. Accuracy was essential. She processed expense reports by entering data into the computer, filed documents, and made travel arrangements. She processed invoices and followed through to ensure that they were paid. She generated briefing material for senior level meetings. She completed internal and external training to better understand United Technologies Corporation business practices and company objectives.”

Around 2008, Spears started taking sick days because of symptoms such as coughing, fever, night sweats, and respiratory problems. She was subsequently treated for asthma symptoms and migraines. Following this, her symptoms “became debilitating in the summer of 2008.” Spears stated that she “could not do her job.” Her issues included lack of ability to focus, blurry vision, migraines, memory problems, a general daze, and problems understanding what her boss needed from her. In September 2008, Spears applied for short-term disability benefits which were granted on September 27. Later, Spears alleged that her application for long-term disability benefits was denied on January 30, 2009, because the “LTD elimination period was not met.”

In May of 2009, Spears’ short-term benefits were limited to February 8, 2009, because the “available records [did] not support any restrictions and limitations or impairment precluding [Spears] from performing the duties of [her] job . . . during the period of February 9, 2009 through the present date.” By October 2009, Spears had provided additional doctor reports explaining that she could not work as a result of her symptoms. She was again denied in January of 2010 for lack of evidence of any limitations, restrictions, or impairment beyond the February 9^th date. This denial was reaffirmed in May, followed by a request for additional information from Spears in June.

By October 2010, UTC had requested that Liberty overrule its denial decision and provide Spears with short-term disability benefits through the remainder of her STD eligibility period. UTC also requested that Liberty open a long-term disability claim and make a determination.

Liberty denied the long-term disability claim, referring back to its prior February denial. Liberty cited lack of medical documentation and failure to satisfy the elimination period, as well as a “September 27, 2010 peer review report.” At this point, Spears noted that the Social Security Administration had granted her application for SSA disability benefits on February 25, 2011, with a disability onset date of August 31, 2008. By May of 2011, Spears had appealed the termination of her long-term disability benefits by providing the Social Security Administration information and “numerous medical records and reports.” This appeal was also denied.

On November 21, 2011, Spears filed suit regarding the denial of her long-term disability benefit plan. She claimed that Liberty and UTC violated the plan’s terms and ERISA “by failing to provide adequate notice in writing setting forth the specific reasons for such denial and by failing to afford a reasonable opportunity to Spears for a full and fair review by the appropriate named fiduciary of the decision her claim for benefits.”

First, the court dismissed UTC as a party because the administrator of the long-term disability benefits is Liberty. The court then found that Liberty did not provide substantial evidence and remanded the matter “with instructions to consider additional evidence unless no new evidence could produce a reasonable conclusion permitting a denial of the claim or remand would otherwise be a useless formality.”

At that point, the lawsuit was closed while the matter was remanded. Additional documentation and medical records were then submitted from August 2015 to March 2016. There were renewed medical analyses and the insurance company obtained an Independent Medical Exam (“IME”).

Spears then filed a new lawsuit on April 11, 2016. The court dismissed said case and instead had the parties reopen the original suit. The parties did so, and Liberty filed the instant Motion to Dismiss. In short, Spears alleged that Liberty and UTC breached their fiduciary duties under ERISA and that she is therefore entitled to disability plan benefits and attorney fees.

The court particularly considered whether it should allow Spears’ suit to move forward in light of any new evidence. However, the court decided that Spears had not raised any additional facts or evidence which would indicate that the disability plan’s language was false or misleading in any way.

As such, the court opined that Spears’ claim could not be reasserted and should be dismissed. In addition, Spears attempted to include UTC as part of the lawsuit a second time. The court however, referenced that it had no reason to disturb its original decision of dismissing UTC since it is not the administrator of long-term disability benefits. Therefore, overall, the court decided to rule in favor of both Liberty and UTC, dismissing Spears’ suit and barring her claims against them.