Ringwald v. Prudential Insurance Co. of America

Eric S. Ringwald’s (plaintiff) long-term disability benefits were discontinued after he received benefits for 24 months due to his depression. The benefits were paid under an employer group insurance plan, which was issued by Prudential Insurance Company of America (defendant) and governed by the Employee Retirement Income Security Act of 1974 (ERISA). The plan paid participants for 24 months if they were unable to perform the substantial duties of their regular employment and lost 20 percent or more of their income due to sickness or injury. After 24 months, the plan discontinued payments unless participants still suffered from the sickness or injury and could not perform any gainful occupation for which they were otherwise suited. The plan limited benefit payments altogether for disabilities due in whole or in part to mental illness, paying participants for only 24 months over their lifetimes. Mental illness was defined as psychiatric or psychological conditions of any kind. The plan provided a nonexclusive list of mental illnesses including depression and bipolar illness and provided that the illnesses were those typically treated by psychiatrists and psychologists with psychotherapy, psychotropic drugs, or similar treatments. In appeal of the discontinuation, Ringwald sent a letter to Prudential from his treating physician who opined that Ringwald had been continuously disabled throughout the relevant period due to his HIV, complications from medication for his HIV, and depression that had physical symptoms, thus could not perform any employment. Ringwald had been treated by the physician for over a decade, having begun seeing the doctor before his HIV diagnosis. After considering a voluminous record of medical reports, medical records, and correspondence, mainly documenting Ringwald’s depression and bipolar disorder and treatment for both, Prudential upheld the discontinuation. Ringwald sought judicial review under ERISA, arguing Prudential abused its discretion by failing to consider an abundance of objective medical evidence that HIV was the basis of his impairments and his inability to perform any work.