Geiger v. Aetna Life Ins. Co.

Dist. Ct. did not err in granting defendant-insurance company’s motion for summary judgment in action under ERISA alleging that defendant wrongfully terminated plaintiff’s long-term disability benefits, after determining that plaintiff could perform two occupations that matched plaintiff’s capabilities. Plaintiff failed to show that her termination of benefits was either arbitrary or capricious, since defendant offered “reasoned explanation” for said termination, where: (1) surveillance evidence of plaintiff performing shopping and driving chores without any assistive device supported defendant’s expert opinion and refuted opinion of plaintiff’s expert; (2) although plaintiff had not previously performed jobs identified by defendant’s expert, terms of plan only required defendant to identify jobs that “may reasonably become” filled by plaintiff due to her education and training. Fact that defendant had previously awarded long-term disability benefits to plaintiff did not require different result, since ERISA allows plan administrators to perform periodic reviews of beneficiaries’ disability status. Also, plaintiff was not entitled to limited discovery on issue of defendant’s potential conflict, where record showed that: (1) defendant obtained numerous independent physician peer reviews before terminating plaintiff’s long-term disability benefits; (2) defendant contacted plaintiff’s own physicians and addressed their concerns; and (3) defendant sent surveillance video to plaintiff’s physicians to ensure that video was assessed objectively.