Klancar v. Hartford Life & Accident Ins. Co.

Klancar v. Hartford Life & Accident Ins. Co.

Opinion

ORDER AND REPORT AND RECOMMENDATION

Plaintiff Patrick Klancar brings this action to recover long-term disability benefits under 29 U.S.C. § 1132(a)(1)(B) of the Employee Retirement Income and Security Act (ERISA), 29 U.S.C. § 1001 et seq., against defendant The Hartford Life and Accident Insurance Company (Hartford). This matter is before the Court on the parties' cross motions for judgment on the administrative record (Docs. 32-1, 36) and responses thereto (Docs. 41, 42). Plaintiff has also filed a motion to strike defendant's statement of proposed undisputed facts (Doc. 32-2), to which a response and reply were filed. (Docs. 38-40).

I. Motion to strike

Plaintiff argues that Hartford's statement of proposed undisputed facts (Doc. 32-2) should be stricken as exceeding Judge McFarland's standing order regarding page limits and inconsistent with the proper method of adjudicating the claim at bar. [*2]  Hartford responds that the filing is consistent with Judge McFarland's standing order regarding motions for summary judgment and that, at most, the remedy should be an opportunity for plaintiff to file a responsive document. Plaintiff argues in reply that such filings are superfluous to the administrative record, which the Court is required to review de novo, and to require a responsive briefing would impose a significant expense.

The Sixth Circuit has held "that summary judgment generally is an inappropriate mechanism for adjudicating ERISA claims for benefits." Univ. Hosps. of Cleveland v. Emerson Elec. Co., 202 F.3d 839, 845 n.2 (6th Cir. 2000) (citing Wilkins v. Baptist Healthcare Sys., Inc., 150 F.3d 609, 617-619 (6th Cir. 1998)). This is the case because, "[g]enerally, a court reviewing a party's ERISA claim cannot consider evidence outside the Administrative Record." Likas v. Life Ins. Co. of N. Am., 222 F. App'x 481, 485 (6th Cir. 2007) (citing Wilkins, 150 F.3d at 619). In McKenna v. Aetna Life Ins. Co., No. 13-cv-12687, 2014 U.S. Dist. LEXIS 150908, 2014 WL 5420217, at *7 (E.D. Mich. Oct. 23, 2014), rev'd on other grounds, 620 F. App'x 445 (6th Cir. 2015), the court considered whether an ERISA plaintiff's proposed exhibit reflecting a "timeline of relevant events" was a relevant aid to the court or an impermissible expansion of the record. The court concluded that the exhibit was unnecessary, construed it as argument beyond local page limit rules, and therefore struck it. Id. at *7-8. The Court finds the reasoning in McKenna persuasive and adopts it in this case.¹ Hartford's proposed statement of undisputed [*3]  facts (Doc. 32-2) will be stricken.

II. Cross Motions for Judgment on the Administrative Record

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