McDonough v. Aetna Life Ins. Co., No. 14-1293 (1st Cir. 2015)
Annotate this CaseAppellant was eligible for disability benefits through an employee welfare benefit plan underwritten by Aetna Life Insurance Company. Appellant successfully applied for long-term disability (LTD) benefits under his plan in 2009. Later that year, Appellant’s LTD benefits were terminated. Appellant brought this suit against Aetna under the Employee Retirement Income Security Act of 1974 alleging wrongful termination of benefits. The federal district court granted summary judgment for Aetna on the benefits-termination claim but applied a $5,000 penalty against Aetna for its failure to produce all relevant plan documents within the statutorily prescribed time. The First Circuit (1) vacated summary judgment with respect to the termination of disability benefits and remanded the issue for further consideration by the claims administrator, holding that Aetna’s decision to terminate Appellant’s LTD benefits was not a reasoned determination; and (2) affirmed the district court’s imposition of a $5,000 penalty for the belated production of a plan document, holding that the amount of the penalty imposed was within the district court’s discretion.
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