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Carpenter v. Aetna Life Insurance Co.

July 31, 2009

THOMAS M. CARPENTER, PLAINTIFF,
v.
AETNA LIFE INSURANCE COMPANY, DEFENDANT.



The opinion of the court was delivered by: David N. Hurd United States District Judge

MEMORANDUM-DECISION and ORDER

I. INTRODUCTION

Plaintiff Thomas M. Carpenter ("plaintiff" or "Carpenter") brings this action against Aetna Life Insurance Company ("defendant" or "Aetna") challenging the termination of his long-term disability benefits under a group insurance policy administered and insured by defendant, as a violation of the Employee Retirement Income and Security Act of 1974 ("ERISA"), 29 U.S.C. §§ 1001-1461.

Defendant moves for summary judgment pursuant to Federal Rule of Civil Procedure 56. Plaintiff opposes defendant's motion, and defendant replies. The motion was taken on submission without oral argument.

II. BACKGROUND

Plaintiff worked as a delivery driver for Sysco Corporation ("Sysco"), and was covered under Sysco's Long-Term Disability Plan (the "Plan"). Aetna administered and insured the Plan and was responsible for making disability determinations. Upon filing a long-term disability ("LTD") benefits claim, plaintiff was entitled to LTD benefits once the Plan's 180-day elimination period (an individual must remain disabled during this period before benefits are paid) expired. The Plan required plaintiff to file proof of claim within ninety days after expiration of the elimination period. In addition, the Plan gave individuals no sooner than sixty days after proof of claim was due and up to three years from the time proof of claim was due to seek judicial relief.

The Plan allowed individuals to receive benefits under the "Own Occupation" and "Reasonable Occupation" standards. Under the "Own Occupation" standard, the Plan paid benefits for twenty-four months if an individual was disabled from performing the necessary duties of their regular occupation. However, after expiration of LTD benefits under the "Own Occupation" standard, the definition to qualify for LTD benefits changed to an individual's inability to perform any "Reasonable Occupation" suited to their education and work experience.

On March 26, 2002, Carpenter suffered a back injury at home, and applied for LTD benefits as allowed under the Plan's "Own Occupation" standard. Upon expiration of the 180-day elimination period, plaintiff was granted and received benefits from September 22, 2002, through September 22, 2004.

By letter dated September 22, 2004, which was the day plaintiff's benefits expired under the "Own Occupation" standard, defendant terminated Carpenter's LTD benefits after determining he was not disabled under the "Reasonable Occupation" standard as defined in the Plan.

On December 13, 2004, plaintiff appealed defendant's decision denying his LTD benefits claim under the "Reasonable Occupation" standard. By written notification dated February 18, 2005, defendant affirmed its prior decision and issued a final denial letter regarding plaintiff's appeal for continuing LTD benefits under the "Reasonable Occupation" standard.

On June 26, 2008, plaintiff commenced the instant civil action by filing a complaint for wrongful denial of LTD benefits under 29 U.S.C. § 1132(a)(1)(B). The original complaint alleged wrongful denial of benefits against plaintiff's employer, Sysco. On October 14, 2008, by the parties' stipulation and order of the court, the action against Sysco was dismissed with prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii). An amended complaint was filed substituting Aetna as a defendant in this action.

III. DISCUSSION

A. Summary Judgment Standard

Summary judgment should be granted "if the pleadings, the discovery and disclosure materials on file, and any affidavits show that there is no genuine issue as to any material fact and that the movant is entitled to judgment as a matter of law." FED. R. CIV. P. 56(c); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247, 106 S.Ct. 2505, 2509-10 (1986); Samuels v. Mockry, 77 F.3d 34, 35 (2d Cir. 1996) (per curiam). All facts, inferences therefrom, and ambiguities must be viewed in a light most favorable to the nonmoving party. Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587, 106 S.Ct. 1348, 1356 (1986); Brown v. Henderson, 257 F.3d 246, 251 (2d Cir. 2001). The moving party carries the initial burden of ...


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