On February 16, 2023, the Chief Judge of the United States District Court for the Northern District of Illinois ruled in favor of one of our clients, a utility machine operator for a large snack food company, in Robinson v. Aetna Life Insurance Company.
Aetna terminated the client’s long-term disability (“LTD”) benefits after paying her claim for 24 months based on a provision in the disability plan that required the client “be receiving Social Security Disability Income (SSDI) benefits by the end of the 24th month of LTD in order to be considered disabled beyond the first 24 months of LTD.” In Robinson’s case, the 24-month period ended on October 29, 2018. Although Robinson had filed a timely application for SSDI benefits, it remained pending at the time she exhausted 24 months of LTD benefits. Robinson appealed Aetna’s termination of her claim, requesting that Aetna toll its review of the appeal until the Social Security Administration (“SSA”) ruled on her SSDI claim. Aetna refused and upheld its termination of benefits on appeal. Meanwhile, the SSA determined on March 27, 2020 that Robinson was entitled to SSDI benefits and retroactively awarded her benefits dating back to October 1, 2016.
After filing suit and defeating Aetna’s attempt to dismiss the case, the district court considered Robinson’s and Aetna’s cross motions for summary judgment. The court found in favor of our client despite applying the highly deferential ‘arbitrary and capricious’ standard of review to Aetna’s benefit determination. The court found Aetna’s interpretation of the plan’s SSDI requirement was unreasonable because Aetna ignored the fact that Robinson’s SSDI award was retroactive to October 1, 2016. Thus, per the court, Robinson effectively began receiving SSDI benefits before the plan’s deadline of October 29, 2018. The court reasoned that, “[b]y common sense, when something happens retroactively, it changes the conditions of the past; the verb tense of the Plan’s provision does not alter the effect of retroactivity.”
The court went on to deem Aetna’s refusal to toll its review of Robinson’s appeal “especially troublesome” given the fact that the SSA’s decision rested entirely outside of her control. Moreover, Aetna’s conduct was inconsistent with the plan’s prior representation that it would assist Robinson apply for SSDI benefits. Finally, the court drew attention to the fact that Aetna possessed the ability under the plan to retroactively recoup any overpayments of LTD claims by the amount a claimant receives in SSDI benefits. Yet, it simultaneously refused to acknowledge the retroactive nature of SSDI awards when applying the plan’s 24-month window to receive such benefits to Robinson’s claim
Therefore, the court remanded Robinson’s claim to Aetna for consideration of whether she satisfied the plan’s additional preconditions for receipt of LTD benefits beyond 24 months.
Shareholder Matthew Maloney represented the client in both the administrative appeal of Aetna’s termination of benefits, as well as at the district court level.