Stewart v. Hartford Life & Accident Ins. Co., Case No. 2:17-CV-01423-KOB
| Decision Date | 06 May 2021 |
| Docket Number | Case No. 2:17-CV-01423-KOB |
| Parties | CAROL H. STEWART, Plaintiff, v. HARTFORD LIFE & ACCIDENT INSURANCE COMPANY, Defendant. |
| Court | U.S. District Court — Northern District of Alabama |
Plaintiff Carol Stewart, like many American workers, participated in an employee-benefit plan that her former employer, the law firm of Burr & Forman, LLP, sponsors. Defendant Hartford Life & Accident Insurance Company administers claims and pays benefits under the plan, and the Employee Retirement Income Security Act of 1974 (ERISA) governs the plan. The Hartford plan provides several benefits for disabled plan participants, including long-term disability insurance and waiver-of-premium benefits for its life insurance policy. This ERISA case involves Ms. Stewart's attempts to secure those benefits.
In 2007, Ms. Stewart's physician diagnosed her with Parkinson's disease. At that time, Burr & Forman sponsored a disability insurance policy for its employees insured by the Sun Life Assurance Company of Canada. In 2009, Sun Life began paying Ms. Stewart partial long-term disability benefits under its disability policy. In 2010, Burr & Forman terminated the Sun Life disability policy and transitioned both disability and life insurance policies to Hartford. And finally, in 2012, two important events occurred: Sun Life began paying Ms. Stewart total long-term disability benefits under its disability policy; at the same time, Ms. Stewart filed claims for total long-term disability benefits and for life-waiver-of-premium benefits under the Hartford disability and life policies. Hartford denied both claims. Those denials led to this case.
Nine years later, this ERISA case—which Ms. Stewart filed in 2017—has finally reached the judgment stage, and the parties have filed their cross-motions for judgment on the pleadings after engaging in extra-record discovery (see doc. 61; 83). But Ms. Stewart hotly contests the facts of this case, so she has also filed a so-called "Motion to Strike and/or Evidentiary Objection." This case now comes before the court on those three motions.
As discussed more fully in this Opinion, the court concludes that Hartford properly gave Ms. Stewart a full and fair review of both her long-term disability and waiver-of-life-premium claims and acted within its discretion in denying those claims. Accordingly, the court will DENY Ms. Stewart's motion for judgment (doc. 96), will GRANT Hartford's motion for judgment (doc. 95), and will enter judgment for Hartford. And because Hartford properly presented the extra-record evidence in this case—or, at least because Ms. Stewart did not properly challenge that evidence—the court will DENY Ms. Stewart's motion to strike (doc. 103).
For sake of clarity, the court will begin its analysis with Ms. Stewart's "Motion to Strike and/or Evidentiary Objections" (doc. 103). This presentation allows the court to resolve the disputed factual issues before it sets out its factual narrative, which in turn promotes transparency in that the court will actually consider all facts set out in the narrative in making its ruling on the motions for judgment.
Before addressing the arguments Ms. Stewart raises in her filing, the court notes here that she had no authority under which to submit that filing. Federal Rule of Civil Procedure 12(f), which governs motions to strike, allows the court to "strike from a pleading an insufficientdefense or any redundant, immaterial, impertinent, or scandalous matter." (Emphasis added). But because briefs are not "pleadings" for the purposes of Rule 12(f), courts in this Circuit generally do not entertain motions to strike briefs. See, e.g., Jordan v. Cobb Cnty., 227 F. Supp. 2d 1322, 1346 (N.D. Ga. 2001) (); Eubanks v. Henry Cnty., No. 1:11-CV-3969-AJB, 2013 WL 11971258, at *1 (N.D. Ga. June 20, 2013) (). Ms. Stewart maintains, however, that she only submitted the filing as a "motion to strike" because she "prepared [it] as an Evidentiary Objection to some of Hartford's alleged facts, but the Court's ECF menu did not provide an option to file the document in this manner." (Doc. 107 at 1).
But Ms. Stewart did not have the authority to submit a separate "evidentiary objection" in this case, either. Ms. Stewart asks this court to sustain her evidentiary objections because Hartford included "inadmissible evidence" in its Statements of Undisputed Facts. (Doc. 103 at 1). And courts generally do allow a party challenging the admissibility of evidence to file an objection to that evidence. See, e.g., Jordan, 227 F. Supp. 2d at 1346 () (citations omitted). But the Federal Rules of Evidence and their admissibility provisions do not apply to ERISA cases. See, e.g., Herman v. Hartford Life & Acc. Ins. Co., 508 F. App'x 923, 928 (11th Cir. 2013) (Table) () (quoting Black v. Long Term Disability Ins., 582 F.3d 738, 746 n.3 (7th Cir. 2009)).
Instead, in ERISA cases courts consider "the facts known to the administrator at the time the decision was made." Glazer v. Reliance Standard Life Ins. Co., 524 F.3d 1241, 1246 (11thCir. 2008) (quoting Jett v. Blue Cross & Blue Shield of Ala., 890 F.2d 1137, 1139 (11th Cir. 1989)). See also Alexandra H. v. Oxford Health Ins. Inc. Freedom Access Plan, 833 F.3d 1299, 1312 (11th Cir. 2016) () (emphasis added). And nowhere in her evidentiary objection does Ms. Stewart claim that Hartford supported its arguments with facts not known to the administrator at the time it made its decision. (See doc. 103). Instead, she makes frivolous and dilatory objections to statements in Hartford's brief and to its interrogatory responses. And as to the evidence in this case, she merely quarrels with the conclusions Hartford draws from that evidence and the interpretations it gives to that evidence. But this court provided Ms. Stewart an avenue to challenge Hartford's interpretations of the record: in her Response brief allowed by Appendix II to this court's ERISA Order (doc. 25 at 13, 16). That Order explicitly states that "[a]ll material facts set forth in the statement requirement of the moving party will be deemed to be admitted...unless controverted by the response of the party opposing [judgment]." (Doc. 25 at 16) (emphasis added).
Accordingly, the court concludes that it has no obligation to entertain Ms. Stewart's "evidentiary objections" and agrees with Hartford that the filing constitutes nothing more than a "blatant attempt to avoid the already extended page limitation for Reply Briefs in this case." (Doc. 106 at 2) (emphasis in original). But because Ms. Stewart's objections also fail on their merits, the court, out of an abundance of caution and to give Ms. Stewart the benefit of the doubt, will explain those reasons.
Ms. Stewart brings three primary challenges in her filing: (1) she challenges the "Introduction and Headings" in Hartford's brief on its motion for judgment (doc. 95-1); (2) she brings a variety of challenges to Hartford's interrogatory responses (doc. 95-2; 95-3); and (3) shebrings a litany of arguments on the merits of this case that she has characterized as "evidentiary objections." (See doc. 103 at 2-11). The court will address each of these challenges in turn.
Ms. Stewart first challenges the introduction in Hartford's "Memorandum of Law in Support of its Motion for Judgment" (doc. 95-1 at 1) and the headings Hartford included in its "Statement of Undisputed Facts" in that filing (doc. 95-1 at 10, 11, 15, 16, 19). Appendix II of this court's standard ERISA Order requires a brief on a motion for judgment to "begin with a statement of allegedly undisputed relevant material facts set out in separately numbered paragraphs." (Doc. 25 at 15) (emphasis omitted). According to Ms. Stewart, Hartford violated Appendix II because it opened its brief with a one-page introduction and included argumentative headings in its Statement of Undisputed Facts. (Doc. 103 at 1-2). Hartford responds that it "[did] not read Appendix II to forbid the inclusion of a brief introduction." (Doc. 106 at 6).
The court agrees with Hartford and will not disregard Hartford's introduction or the headings in its Statement of Undisputed Facts. Hartford included its introduction and headings on numbered pages; Hartford used its page allocation as it saw fit and in compliance with Appendix II. It did not, for example, use the introduction as a mechanism to make merits arguments outside of Appendix II's page limitations. Unfortunately, it appears to the court that Ms. Stewart, on the other hand, included her objection to Hartford's introduction and headings to disguise the true purpose of her pleading: an effort to make additional merits arguments outside of the briefing allowed by Appendix II and this court's Briefing Schedule. (Doc. 25 at 17; doc. 86). This groundless argument fails.
Ms. Stewart next brings a variety of challenges to Hartford's interrogatory responses (doc. 95-2; 95-3). This court allowed limited extra-record discovery in this case, mainly in the form of interrogatories and requests for production from Ms. Stewart to Hartford. (See doc. 61; 83). Ms. Stewart claims that Hartford failed to adequately answer all of her interrogatories, made improper objections to those...
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