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Lee v. Hartford Life & Acc. Ins. Co.

United States District Court, District of Columbia

March 5, 2013

Debra LEE, Plaintiff,
v.
HARTFORD LIFE & ACCIDENT INSURANCE COMPANY et al., Defendants.

Page 52

Scott Bertram Elkind, Elkind & Shea, Silver Spring, MD, for Plaintiff.

Brian Patrick Downey, Pepper Hamilton LLP, Harrisburg, PA, Joleen Okun, Ogletree, Deakins, Nash, Smoak & Stewart, P.C., Washington, DC, Vance E. Drawdy, Ogletree, Deakins, Nash, Smoak & Stewart, P.C., Greenville, NC, for Defendants.

MEMORANDUM OPINION

RUDOLPH CONTRERAS, District Judge.

I. INTRODUCTION

Debra Lee brings this action under the Employee Retirement Income Security Act of 1974 (" ERISA" ), 29 U.S.C. § 1001 et seq., claiming that her insurance company— The Hartford Life and Accident Insurance Company— wrongfully denied her claim for disability benefits. In her motion for partial summary judgment, the

Page 53

plaintiff asks whether she may supplement the record with documents that were not in the record at the time Hartford denied her claim. Ordinarily, the record is confined to " the evidence presented to the plan administrators, not ... a record later made in another forum." Heller v. Fortis Benefits Ins. Co., 142 F.3d 487, 493 (D.C.Cir.1998). This case is no different. Accordingly, the court will deny the plaintiff's motion.

II. FACTUAL ALLEGATIONS AND PROCEDURAL BACKGROUND

Through her former employer, Debra Lee was enrolled in an insurance plan that covered claims for disability benefits. Am. Compl. ¶ 6. Hartford is the claims administrator [1] and insurer for the plan. Id. ¶ 7. Ms. Lee alleges that she suffers from several medical conditions that render her disabled under the insurance contract, thereby entitling her to receive disability benefits. Id. ¶¶ 10-11. She began receiving such benefits in 2007. Id. Two years later, based on a change in the contractual definition of " disabled," Hartford concluded that Ms. Lee no longer met the policy's definition of " disabled" and thus denied her claim for continued payments. See id. ¶¶ 9, 12; Pl.'s Mot., Ex. 1. In early 2010, Ms. Lee internally appealed Hartford's decision. Am. Compl. ¶ 12; Pl.'s Mot., Ex. 3. When reviewing her appeal, Hartford solicited the views of a medical professional, Dr. Ephraim Brennan. Def.'s Opp'n at 2. After reviewing the evidence, Hartford denied Ms. Lee's appeal. Pl.'s Mot., Ex. 3. Hartford did not give Ms. Lee the opportunity to review or rebut Dr. Brennan's report before deciding her appeal. Pl.'s Mot. at 3; Def.'s Opp'n at 3.

Ms. Lee brought suit under 29 U.S.C. § 1132(a), alleging that Hartford's internal appeals process was unfair and that Hartford suffers from a conflict of interest. Now before the court is the plaintiff's motion for partial summary judgment, in which she asks the court to supplement the record with additional documents (rather than for partial judgment in her favor). See Pl.'s Reply at 14, 15 (requesting an opportunity to respond to Dr. Brennan's report). Accordingly, the court construes the motion as a motion to supplement the record.

III. ANALYSIS

A. Legal Framework

" ERISA is a comprehensive statute designed to promote the interests of employees and their beneficiaries in employee benefit plans." Shaw v. Delta Air Lines, Inc., 463 U.S. 85, 90, 103 S.Ct. 2890, 77 L.Ed.2d 490 (1983); see also 29 U.S.C. § 1001(b) (noting that ERISA was enacted " to protect ... employee benefit plans and their beneficiaries" ). Among those plans regulated by ERISA are employer-sponsored welfare plans that provide " benefits in ...


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