Orzechowski v. Boeing Co. Non-Union Long-Term Disability Plan

Talana Orzechowski (plaintiff) was an employee at the Boeing Company (Boeing) (defendant) when she was diagnosed with chronic fatigue syndrome and fibromyalgia. Due to her condition, Orzechowski experienced a number of physical and psychological symptoms that left her unable to work, even to perform light duty, according to her physician. Orzechowski was receiving benefits under Boeing’s long-term disability insurance until Boeing’s plan administrator, Aetna Life Insurance Company (Aetna), determined that Orzechowski no longer qualified for benefits. Boeing’s plan documents contained discretionary clauses allowing Aetna to make benefit determinations. Aetna’s doctors conducted multiple reviews of medical documents and letters from Orzechowski’s doctor, and Aetna’s neurologist determined that Orzechowski’s condition had to be mental in origin because there was no specific neurologic diagnosis. Therefore, Orzechowski’s condition fell into the plan’s limitation of only 24 months of benefit payments for mental-health conditions. Aetna determined Orzechowski could perform light duty and that she was not completely disabled, which meant Orzechowski would no longer receive payments under Boeing’s long-term disability plan. Orzechowski appealed to a federal district court for review under the Employment Retirement Income Security Act (ERISA). If a benefit plan contained a discretionary clause, a court would review a plan administrator’s denial of benefits using the abuse-of-discretion standard instead of the de novo standard. However, California had passed a law voiding discretionary clauses in benefit plans related to life and disability insurance. Despite this, a district court judge determined that California’s law was not applicable to Boeing’s benefit plans and used the abuse-of-discretion standard in affirming Aetna’s decision to deny Orzechowski long-term disability benefits. Orzechowski appealed.