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Riley v. Aetna Life Insurance Co.

United States District Court, D. Colorado

April 13, 2015

MICHAEL RILEY, Plaintiff,
v.
AETNA LIFE INSURANCE COMPANY, a Connecticut corporation, Defendant.

ORDER AFFIRMING AGENCY ACTION

ROBERT E. BLACKBURN, District Judge.

This matter is before me on Plaintiff's Opening Brief [#29], [1] filed January 12, 2014. In this action, plaintiff seeks review of defendant's decision to terminate his long-term disability benefits. I affirm that decision.

I. JURISDICTION

I have jurisdiction of this matter pursuant to 29 U.S.C. § 1132(e) (authority to review denial of benefits under an ERISA plan).

II. STANDARD OF REVIEW

There is no dispute in this case that defendant's long-term disability plan is an ERISA plan. Moreover, the parties agree that defendant's decision to terminate plaintiff's benefits under the plan may be set aside only if it was arbitrary and capricious. See Cardoza v. United of Omaha Life Insurance Co., 708 F.3d 1196, 1201 (10th Cir. 2013).[2] Under this standard, "review is limited to determining whether the interpretation of the plan was reasonable and made in good faith." LaAsmar v. Phelps Dodge Corp. Life, Accidental Death & Dismemberment & Dependent Life Insurance Plan, 605 F.3d 789, 796 (10th Cir. 2010) (citation and internal quotation marks omitted). The administrator's decision will be affirmed "so long as it is predicated on a reasoned basis." Adamson v. Unum Life Insurance Co. of America, 455 F.3d 1209, 1212 (10th Cir. 2006). See also Kimber v. Thiokol Corp., 196 F.3d 1092, 1098 (10th Cir. 1999) (administrator's decision must be upheld "unless it is not grounded on any reasonable basis") (citations and internal quotation marks omitted; emphasis in original).

"Certain indicia of an arbitrary and capricious denial of benefits include lack of substantial evidence, mistake of law, bad faith, and conflict of interest by the fiduciary." Graham v. Hartford Life & Accident Insurance Co., 589 F.3d 1345, 1357 (10th Cir. 2009), cert. denied, 130 S.Ct. 3356 (2010) (citation and internal quotation marks omitted). Substantial evidence is defined as "more than a scintilla but less than a preponderance." Sandoval v. Aetna Life & Casualty Insurance Co., 967 F.2d 377, 382 (10th Cir. 1992). Stated differently, substantial evidence "is such evidence that a reasonable mind might accept as adequate to support the conclusion reached by the decisionmaker." Id. (citations and internal quotation marks omitted). Thus,

[u]nder the arbitrary and capricious standard of review, [defendant's] decision need not be the only logical decision nor even the best decision. Rather, the decision need only be sufficiently supported by facts known to [defendant] to counter a claim that the decision was arbitrary or capricious.

Williams v. Metropolitan Life Insurance Co., 2011 WL 97137 at *3 (D. Colo. Jan. 11, 2011) (Blackburn, J.), aff'd, 459 Fed.Appx. 719 (10th Cir. Feb. 7, 2012).

III. ANALYSIS

Plaintiff was employed by Sprint Nextel as an engineer and manager. Sprint employees are entitled to disability benefits under an ERISA plan, of which defendant is the administrator. The plan provides two different tests of disability, depending on how long the disability has lasted:

From the date that you first become disabled and until Monthly Benefits are payable for 24 months, you will be deemed to be disabled on any day if:
• you are not able to perform the material duties of your own occupation solely because ...

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