Hasan v. Reliance Standard Life Insurance Company

Filing 24

ORDER granting 10 Motion for Judgment; denying 11 Motion for Summary Judgment; adopting 21 Report and Recommendation. Signed by District Judge Arthur J. Tarnow. (MLan)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
PAMALA HASAN,
Case No. 10-14043
Plaintiff,

Senior U.S. District Judge Arthur J. Tarnow
Magistrate Judge R. Steven Whalen

v.
RELIANCE STANDARD LIFE INSURANCE COMPANY,
Defendant.

ORDER ADOPTING MAGISTRATE JUDGE’S REPORT & RECOMMENDATION [21],
OVERRULING PLAINTIFF’S OBJECTION [22], DENYING PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT [11], AND GRANTING DEFENDANT’S MOTION FOR
JUDGMENT ON THE ADMINISTRATIVE RECORD [10]

Before the Court are Plaintiff’s Motion for Summary Judgment [11] and Defendant’s
Motion for Judgment on the Administrative Record [10]. On March 7, 2012, Magistrate Judge
Whalen issued a Report and Recommendation [21] (“R&R”) recommending that the Plaintiff’s
motion be DENIED and that Defendant’s motion be GRANTED. Plaintiff filed an Objection
[22]. Defendant filed a Response [23].
The standard of review set forth in Federal Rule of Civil Procedure 72(b) governs this
dispositive matter. Fed. R. Civ. P. 72(b). Pursuant to that rule, “[t]he district judge in the case
must determine de novo any part of the magistrate judge’s disposition that has been properly
objected to.” Id. at 72(b)(3); see also 28 U.S.C. § 636(b)(1)(C) (2006).

Plaintiff seeks benefits for Long Term Disability (“LTD”) benefits pursuant to the
Employee Retirement Income Security Act (ERISA). 29 U.S.C. § 1001 et seq. Plaintiff raises
two main objections to the R&R: 1) that the Magistrate Judge applied the wrong standard of
review and 2) that the Magistrate Judge erred in finding that Defendant provided a reasoned
explanation for the denial of benefits. See Obj. [22]. For the reasons stated below, the Court
overrules Plaintiff’s objections.
First, Plaintiff argues that the Magistrate Judge erred in applying an “arbitrary and
capricious” standard of review. Obj. [22], at 7-9. As the Magistrate Judge stated, the language of
the plan is clear. It affords the decision-maker with discretionary authority to determine
eligibility for benefits. The Magistrate Judge did not err in applying an “arbitrary and capricious”
standard of review. See McDonald v. W.-S. Life Ins. Co., 347 F.3d 161, 168-69 (6th Cir. 2003)
(holding that when a plan administrator has discretionary authority to determine eligibility for
benefits an “arbitrary and capricious” standard of review is used).
Second, Plaintiff argues that the even under the arbitrary and capricious standard,
Defendant failed to provide a reasoned explanation for the denial of benefits. Obj. [22], at 9-13.
The Court disagrees. As the Magistrate Judge explained, the potential conflict of interest related
to Defendant’s relationship with its own consulting physicians was taken into account in the
R&R, as was Plaintiff’s favorable Social Security Disability decision. Nevertheless, Defendant
provided a reasoned explanation for its decision.
CONCLUSION
Based on the foregoing analysis, the Court hereby ADOPTS the Report and
Recommendation [21] as the findings and conclusions of the Court. Therefore,

IT IS ORDERED that Plaintiff’s Objection [22] is OVERRULED and Plaintiff’s Motion
for Summary Judgment [11] is DENIED.
IT IS FURTHER ORDERED that Defendant’s Motion for Judgment on the
Administrative Record [10] is GRANTED.
SO ORDERED.

s/Arthur J. Tarnow
ARTHUR J. TARNOW
SENIOR U.S. DISTRICT JUDGE
Dated: March 30, 2012