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Reetz v. Hartford Life and Accident Insurance Co.

United States District Court, W.D. Washington, Seattle

November 8, 2017





         Before the court is Plaintiff Kristen Reetz's motion to supplement the administrative record in this action with the Social Security Administration's (“SSA”) determination that she is disabled and the vocational evidence presented at the SSA hearing. (Mot. (Dkt. # 14).) Having considered the parties' submissions, the relevant portions of the record, and the applicable law, the court DENIES Ms. Reetz's motion to supplement.


         This case arises from Defendant Hartford Life and Accident Insurance Company's (“Hartford”) termination of Ms. Reetz's long-term disability (“LTD”) benefits. (Compl. (Dkt. # 1) ¶¶ 5.2-5.5.) Ms. Reetz was at all times a participant, as defined by the Employee Retirement Income Security Act (“ERISA”), 29 U.S.C. § 1002(7), in a Group Long Term Disability Plan (the “Plan”) provided by Hartford (Compl. ¶¶ 4.6-4.14). The Plan is an “employee benefit plan” as defined by ERISA. See 29 U.S.C. § 1002(3). Hartford issues benefits for those who meet the terms and conditions of the Plan. (Compl. ¶ 4.7.)

         As a result of an illness that began on or about March 7, 2014, Ms. Reetz was allegedly unable to perform one or more of the essential duties of her job. (Id. ¶ 4.19.) Hartford determined that Ms. Reetz was disabled within the meaning of the Plan and began paying her LTD benefits on June 6, 2014. (Id. ¶ 4.21.)

         On October 24, 2014, Hartford advised Ms. Reetz that she must apply to the SSA for Social Security Disability Insurance (“SSDI”) benefits. (Id. ¶ 4.23.) SSDI benefits would offset any LTD payments that Hartford made to Ms. Reetz. (Administrative Record (Dkt. # 15) (“AR”) at 6-7, 18, 22, 449, 459.) Hartford provided Ms. Reetz with attorneys who assisted her in submitting a SSDI application. (Compl. ¶ 4.24.) Although Ms. Reetz's application was initially denied, Ms. Reetz filed a request for reconsideration and initiated the SSA administrative appeal process. (See Id. ¶¶ 4.25-4.29.)

         On April 28, 2016, as Ms. Reetz's SSA appeal was pending, Hartford terminated Ms. Reetz's LTD benefits, explaining via letter that she no longer qualified as disabled under the Plan. (Id. ¶ 4.31.) Ms. Reetz, without representation, appealed the benefit termination in May. (Id. ¶ 4.34.) Hartford informed Ms. Reetz that “it is her responsibility to provide info[rmation] on appeal and [that] she may submit whatever she chooses.” (Id. ¶ 4.35.)

         Two months later, on July 30, 2016, the SSA determined that Ms. Reetz was disabled based on the testimony of a vocational expert, Dr. Paul Prachyl. (Id. ¶ 4.36; Reetz Decl. (Dkt. # 16) ¶¶ 9-10, Ex. 7 at 27.) Due to the award of SSDI benefits, Ms. Reetz repaid Hartford $28, 817.99 on August 4, 2016. (AR at 538.)

         On August 19, 2016, Hartford denied Ms. Reetz's appeal of the termination of benefits. (Id. at 324-29.) Hartford stated that it considered the “SSA's disability determination as one piece of relevant evidence” but determined that the ultimate decision of non-disability was “based on vocational evidence which the SSA is not required to use in the same way.” (Id. at 328-29.) Having exhausted her administrative remedies, Ms. Reetz initiated this suit in federal court. (See generally Compl.) Hartford's claim file-the current administrative record-contains neither the SSA's disability determination nor Dr. Prachyl's testimony. (Crawford Decl. (Dkt. # 15) ¶ 4; see generally AR.)

         III. ANALYSIS

         Ms. Reetz moves the court to supplement the existing administrative record with the SSA's disability determination and Dr. Prachyl's testimony at the hearing. (Mot. at 1.) Hartford opposes the motion and argues that Ms. Reetz has not shown any exceptional circumstances that would warrant supplementing the administrative record. (Resp. (Dkt. # 24) at 1.)

         The parties agree that the court's review of Hartford's benefit determination is de novo. (See Mot. at 5-6; Resp. at 1-2; Crawford Decl. ¶ 5.) Under de novo review, “[t]he court simply proceeds to evaluate whether the plan administrator correctly or incorrectly denied benefits.” Abatie v. Alta Health & Life Ins. Co., 458 F.3d 955, 963 (9th Cir. 2006). The administrator's decision is accorded no deference. Kearney v. Standard Ins. Co., 175 F.3d 1084, 1090 n.2 (9th Cir. 1999). The court evaluates whether the claimant was “entitled to benefits based on the evidence in the administrative record and other evidence as might be admissible under the restrictive rule of [Mongeluzo v. Baxter Travenol Long Term Disability Benefits Plan, 46 F.3d 938, 943 (9th Cir. 1995)].” Opeta v. Nw. Airlines Pension Plan for Contract Emps., 484 F.3d 1211, 1217 (9th Cir. 2007) (internal quotation marks omitted).

         In Mongeluzo, the Ninth Circuit explained that “[i]n most cases . . . the district court should only look at the evidence that was before the plan administrator . . . at the time of the determination.” 46 F.3d at 944. This restriction to the administrative record is based on the principle that district courts “should not function ‘as substitute plan administrators, ' and that expanding the record on appeal ‘would frustrate the goal of prompt resolution of claims by the fiduciary under the ERISA scheme.'” Dorsey v. Metro. Life Ins. Co., No. 2:15-cv-02126-KJM-CKD, 2017 WL 3720346, at *10 (E.D. Cal. Aug. 29, 2017) (quoting Taft v. Equitable Life Assurance Soc'y, 9 F.3d 1469, 1472 (9th Cir. 1993)). Evidence outside of the administrative record is considered “only when circumstances clearly establish that additional evidence is ...

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