On December 23, 2008, the U.S. District Court for the District of New Jersey determined that bipolar disorder was reasonably considered a “Mental Illness” under the ERISA-governed long-term disability policy at issue. The plaintiff in Doe v. Hartford Life and Accident Insurance Company brought suit individually and on behalf of a putative class, alleging that Hartford improperly terminated his long-term disability benefits after 24 months because bipolar disorder is not a “Mental Illness,” as that term was defined in his policy. Plaintiff’s allegations were based on his treating psychiatrist’s opinion that bipolar disorder is a “biological illness.”
In upholding the defendant’s benefits determination as being reasonable, the court applied a deferential abuse of discretion standard of review. In doing so, the court examined whether the deference given to the defendant should be altered based on the Supreme Court’s recent decision in Metropolitan Life Insurance Company v. Glenn. The court analyzed whether the defendant’s structural conflict of interest, as both the claims payor and administrator, affected its decision-making process when it adjudicated the plaintiff’s benefit claim, including whether there was evidence of biased claims decisions. The court concluded that there was no evidence of bias in the record to support decreasing the applicable level of deference. Ultimately, the court concluded that the administrator’s interpretation of the “Mental Illness” definition as including bipolar disorder was clearly reasonable.
Cases challenging whether mental illness definitions in ERISA-governed plans include bipolar disorder because of its purported biological cause have been litigated in a number of courts. This decision is in contrast to a number of those cases, decided under the de novo standard of review, which have held that bipolar disorder’s status as a mental illness cannot be summarily decided. Jorden Burt acted as counsel for the defendant.