A plan administrator's decision is arbitrary and capricious if it lacks a principled reasoning process connecting medical evidence to a claimant's ability to perform specific job duties.
An employee sued her benefit plan administrator for wrongful denial of long-term disability benefits following a spinal injury. The administrator denied the claim by reciting medical documentation without providing a reasoned explanation of how the claimant's medical condition affected her ability to perform her specific job duties. The court held that an administrator's decision is arbitrary and capricious if it lacks a deliberate, principled reasoning process, noting that medical data alone cannot produce a logical judgment about work ability. Because the issue concerned the integrity of the decision-making process rather than a clear entitlement to benefits, the court vacated the judgment and remanded the case for a full and fair review.
At page 621 Reviewing file-only determinations raises questions about thoroughness57 citing cases“courts may either award benefits to the claimant or remand to the plan administrator.”
- Canter v. Alkermes Blue Care Elect Preferred Provider Plan, No. 1:17-cv-00399 (S.D. Ohio Jan. 22, 2020). See Elliott, 473 F.3d at 622 (“[A] remand to the district court with instructions to remand to [the claims administrator] for a full and fair inquiry is the proper remedy here. ...
- Myers v. Mut. of Omaha Life Ins., 175 F. Supp. 3d 820 (N.D. Ohio 2016).published Elliott, 473 F.3d at 622-23 (“We are not medical specialists and that judgment is not ours to make.”).
- Zenadocchio v. BAE Sys. Unfunded Welfare Benefit Plan, 936 F. Supp. 2d 868 (S.D. Ohio 2013).published Co., 437 Fed.Appx. 372, 379 (6th Cir.2011) (distinguishing from Rose , wherein “the claimant was surveilled as she conducted herself in a manner contrary to her claimed level of functionality”); Elliott, 473 F.3d at 618 (“[M]edieal data, w…
- Thomas Judge v. Metro. Life Ins. Co., 710 F.3d 651 (6th Cir. 2013).published Co., 473 F.3d 613, 619 (6th Cir. 2006) (“Dr. Menotti’s review bears a striking resemblance to MetLife’s first denial letter.”); Burge v. Republic Engineered Prods., Inc., 432 F. App’x 539, 550 (6th Cir. 2011) (concluding that Republic’s re…
- Jalali v. UNUM Life Ins. Co. of Am., No. 2:20-cv-05071 (S.D. Ohio Mar. 28, 2022). Although the Court’s review is deferential, “it is not a rubber stamp for the administrator’s determination.” Id. (“[D]eferential review is not no review.”).
- Miller v. Aetna Life Ins. Co., No. 2:19-cv-00500 (S.D. Ohio May 4, 2020). Although the Court's review is deferential, “it is not a rubber stamp for the administrator's determination.” Id. (“[D]eferential review is not no review.”).
- Haning v. Hartford Life & Accident Ins., 140 F. Supp. 3d 654 (S.D. Ohio 2015).published Although the Court’s review is deferential, “it is not a rubber stamp for the administrator’s determination.” Id. (“[D]eferential review is not no review.”).
- Chalk, No. 3:25-cv-00133 (W.D. Ky. Oct. 27, 2025).Ultimately, the court chose to remand to the administrator, explaining that “where the problem is with the integrity of the plan’s decision-making process, rather than that a claimant was denied benefits to which he was clearly entitled, t…
- Engweiler v. Howmet Aerospace Inc., No. 1:24-cv-00975 (W.D. Mich. Aug. 12, 2025).Co., 473 F.3d 613, 621 (6th Cir. 2006).
- Stover v. Carefactor, 718 F. Supp. 3d 745 (S.D. Ohio 2024).publishedCo., 473 F.3d 613, 621 (6th Cir. 2006).
Show 45 more citing cases
- Card v. Principal Life Ins. Co., No. 5:15-cv-00139, 2023 WL 5706202 (E.D. Ky. Sept. 5, 2023).Co. 473 F.3d 613, 621-22 (6th Cir. 2006), the Sixth Circuit explained that “[i]f a court concludes that an administrator acted arbitrarily and capriciously, it may either remand the case to the administrator for a new review or award benef…
- Harmon v. Unum Life Ins. Co. of Am., No. 1:20-cv-00318 (E.D. Tenn. June 23, 2023). Co., 473 F.3d 613, 620 (6th Cir. 2006).
- Bulas v. UNUM Life Ins. Co. of Am., No. 2:22-cv-00112 (S.D. Ohio June 12, 2023).Co., 473 F.3d 613, 621 (6th Cir. 2006).
- Kramer v. Am. Elec. Power Exec. Severance Plan, No. 2:21-cv-05501 (S.D. Ohio Apr. 13, 2023).Co., 473 F.3d 613, 621 (6th Cir. 2009))).
- Snowden v. Hartford Life & Accident Ins. Co., No. 5:21-cv-00144 (E.D. Ky. Mar. 21, 2023). Co., 473 F.3d 613, 621 (6th Cir. 2006).
- Caudill v. Hartford Life & Accident Ins. Co., No. 1:19-cv-00963 (S.D. Ohio Mar. 1, 2023).Co., 473 F.3d 613, 621 (6th Cir. 2006).
- Cohn v. W. & S. Fin. Grp. Long Term Incentive & Retention Plan I, No. 1:19-cv-00943 (S.D. Ohio Sept. 28, 2022).Co., 473 F.3d 613, 621 (6th Cir. 2006).
- Vest v. Nissan Supplemental Exec. Ret. Plan II, No. 3:19-cv-01021 (M.D. Tenn. Aug. 29, 2022).Co., 473 F.3d 613, 621 (6th Cir. 2006); DeGrado v. Jefferson Pilot Fin.
- Carney v. UNUM Life Ins. Co. of Am., 596 F. Supp. 3d 845 (E.D. Mich. 2022).publishedCo., 473 F.3d 613, 621 (6th Cir.2006))(citation cleaned up).
- Whetstone v. United of Omaha Life Ins. Co., No. 2:20-cv-03756 (S.D. Ohio Mar. 28, 2022). Co., 473 F.3d 613, 621 (6th Cir. 2006).
- James Neaton v. Hartford Life & Accident Ins. Co., 517 F. App'x 475 (6th Cir. 2013).unpublished
- Susan Card v. Principal Life Ins. Co., 17 F.4th 620 (6th Cir. 2021).published
- Schwarzwaelder v. Merrill Lynch & Co., 606 F. Supp. 2d 546 (W.D. Pa. 2009).published
- Christina Hunter v. Life Ins. Co. of North Am., 437 F. App'x 372 (6th Cir. 2011).unpublished
- Hoffman v. Nationwide Mut. Ins. Co. Short-Term Disability Plan, No. 2:19-cv-04360 (S.D. Ohio Sept. 22, 2021).
- Daft v. Advest, Inc., 658 F.3d 583 (6th Cir. 2011).published
- Melvin McCollum v. Life Ins. Co. of N. Am., 495 F. App'x 694 (6th Cir. 2012).unpublished
- Shelby Cnty. Health Care Corp. v. Majestic Star Casino, LLC, 581 F.3d 355 (6th Cir. 2009).published
- Bennett v. Kemper Nat'l Servs., Inc., 514 F.3d 547 (6th Cir. 2008).published
- Pitts v. Prudential Ins. Co. of Am., 534 F. Supp. 2d 779 (S.D. Ohio 2008).published
- Kushner v. Lehigh Cement Co., 572 F. Supp. 2d 1182 (C.D. Cal. 2008).published
- DiGiallonardo v. Saint-Gobain Ret. Income Grp., 697 F. Supp. 2d 173 (D. Mass. 2010).published
- Haisley v. Sedgwick Claims Mgmt. Servs., Inc., 776 F. Supp. 2d 33 (W.D. Pa. 2011).published
- Ward v. Cigna Life Ins. Co. of New York, 776 F. Supp. 2d 155 (W.D.N.C. 2011).published
- Nickel v. Unum Life Ins. Co. of Am., 582 F. Supp. 2d 869 (E.D. Mich. 2008).published
- Blajei v. Sedgwick Claims Mgmt. Servs., Inc., 721 F. Supp. 2d 584 (E.D. Mich. 2010).published
- Edward Fura v. Fed. Express Corp. Long Term Disability, 534 F. App'x 340 (6th Cir. 2013).unpublished
- Kennard v. Means Indus., Inc., 660 F. App'x 333 (6th Cir. 2016).unpublished
- Jensen v. Aetna Life Ins., 32 F. Supp. 3d 894 (W.D. Tenn. 2014).published
- Schultz v. PNC Fin. Servs. Grp., Inc., 58 F. Supp. 3d 782 (E.D. Ky. 2014).published
- Songer v. Reliance Stand. Life Ins., 106 F. Supp. 3d 664 (W.D. Pa. 2015).published
- Satterwhite v. Metro. Life Ins., 803 F. Supp. 2d 803 (E.D. Tenn. 2011).published
- Reid v. Metro. Life Ins., 944 F. Supp. 2d 1279 (N.D. Ga. 2013).published
- Minutello v. Hartford Life & Accident Ins., 964 F. Supp. 2d 491 (W.D. Pa. 2013).published
- Arquilla-Romeo v. Metro. Life Ins., 980 F. Supp. 2d 847 (N.D. Ohio 2013).published
- Smith v. Hartford Life & Accident Ins. Co., No. 5:19-cv-00061 (E.D. Ky. July 29, 2020).
- Perkins v. Gen. Motors, LLC, No. 4:16-cv-14465 (E.D. Mich. Jan. 26, 2022).
- Lloyd v. Procter & Gamble Disability Benefit Plan, No. 1:18-cv-00032 (S.D. Ohio Dec. 3, 2020).
- Joyce v. Life Ins. Co. of North Am., No. 2:18-cv-01293 (W.D. Pa. Feb. 10, 2021).
- Sullivan v. Nissan Supplemental Exec. Ret. Plan II, No. 3:20-cv-00752 (M.D. Tenn. July 6, 2021).
- Linda Burge v. Repub. Engineered Prods., Inc., 432 F. App'x 539 (6th Cir. 2011).unpublished
- Susan Card v. Principal Life Ins. Co., 790 F. App'x 730 (6th Cir. 2019).unpublished
- Bustetter v. Stand. Ins. Co., 529 F. Supp. 3d 693 (E.D. Ky. 2021).published
- Goetz v. Greater Georgia Life Ins., 649 F. Supp. 2d 802 (E.D. Tenn. 2009).published
- Reid v. Intern. Painters & Allied Trades Indus., 358 F. Supp. 3d 714 (S.D. Ohio 2019).published
At page 622 Determining appropriate remedy for flawed administrative decision-making56 citing cases“where the problem is with the integrity of the plan's decision-making process, rather than that a claimant was denied benefits to which he was clearly entitled, the appropriate remedy generally is remand to the plan administrator.”
- Smith v. Reliance Stand. Life Ins. Co., No. 4:21-cv-00128 (W.D. Ky. Feb. 15, 2024). Co., 473 F.3d 613, 620 (6th Cir. 2006) (“Generally speaking, a plan may not reject summarily the opinions of a treating physician, but must instead give reasons for adopting an alternative opinion.”) (citation omitted).
- Canter v. Alkermes Blue Care Elect Preferred Provider Plan, No. 1:17-cv-00399 (S.D. Ohio Jan. 22, 2020). ([A] remand to the district court with instructions to remand to [the claims administrator] for a full and fair inquiry is the proper remedy here. ... Such a remedy will allow fora proper determination of whether, in th…)
- Myers v. Mut. of Omaha Life Ins., 175 F. Supp. 3d 820 (N.D. Ohio 2016).published (We are not medical specialists and that judgment is not ours to make.)
- Zenadocchio v. BAE Sys. Unfunded Welfare Benefit Plan, 936 F. Supp. 2d 868 (S.D. Ohio 2013).published Co., 437 Fed.Appx. 372, 379 (6th Cir.2011) (distinguishing from Rose , wherein “the claimant was surveilled as she conducted herself in a manner contrary to her claimed level of functionality”); Elliott, 473 F.3d at 618 (“[M]edieal data, w…
- James Kitchen v. Catherine Bauman, 629 F. App'x 743 (6th Cir. 2015).unpublished Co., 473 F.3d 613 , 622–23 (6th Cir. 2006) (“We are not medical specialists and that judgment is not ours to make.”).
- T. E. v. Anthem Blue Cross Blue Shield, 165 F.4th 971 (6th Cir. 2026).published Co., 473 F.3d 613, 620 (6th Cir. 2006).
- Chalk, No. 3:25-cv-00133 (W.D. Ky. Oct. 27, 2025).Ultimately, the court chose to remand to the administrator, explaining that “where the problem is with the integrity of the plan’s decision-making process, rather than that a claimant was denied benefits to which he was clearly entitled, t…
- Sherry Laake v. Benefits Comm. W&S Fin. Grp., 68 F.4th 984 (6th Cir. 2023).publishedCo., 473 F.3d 613, 622 (6th Cir. 2006) (“Thus, we believe that a remand to the district court with instructions to remand to [the administrator] for a full and fair inquiry is the proper remedy here. . . .
- Masevice v. Life Ins. Co. of North Am., No. 1:22-cv-00223 (N.D. Ohio Mar. 16, 2023).Co., 473 F.3d 613, 622 (6th Cir. 2006). -8- A remand to the Plan Administrator is appropriate in an ERISA case where the problem is with the Plan's decision-making process, rather than that a claimant was denied benefits to which he was cl…
- Zucca v. First Energy Serv. Co., 642 F. Supp. 3d 621 (N.D. Ohio 2022).published Co., 473 F.3d 613, 622 (6th Cir. 2006). “[W]here the problem is with the integrity of the plan’s decision-making process, rather than that a claimant was denied benefits to which he was clearly entitled, the appropriate remedy generally is…
Show 44 more citing cases
- Willard v. Unum Life Ins. Co. of Am., No. 1:20-cv-00125 (E.D. Tenn. Mar. 9, 2022). Co., 473 F.3d 613, 622 (6th Cir. 2006).
- Patti Okuno v. Reliance Stand. Life Ins. Co., 836 F.3d 600 (6th Cir. 2016).published
- Bustetter v. Stand. Ins. Co., No. 0:18-cv-00001 (E.D. Ky. Sept. 24, 2019).
- Raymond Shaw v. AT&T Umbrella Benefit Plan, 795 F.3d 538 (6th Cir. 2015).published
- Christina Hunter v. Life Ins. Co. of North Am., 437 F. App'x 372 (6th Cir. 2011).unpublished
- Vicki Koning v. United of Omaha Life Ins., 627 F. App'x 425 (6th Cir. 2015).unpublished
- Daft v. Advest, Inc., 658 F.3d 583 (6th Cir. 2011).published
- Pitts v. Prudential Ins. Co. of Am., 534 F. Supp. 2d 779 (S.D. Ohio 2008).published
- Nickel v. Unum Life Ins. Co. of Am., 582 F. Supp. 2d 869 (E.D. Mich. 2008).published
- Blajei v. Sedgwick Claims Mgmt. Servs., Inc., 721 F. Supp. 2d 584 (E.D. Mich. 2010).published
- Edward Fura v. Fed. Express Corp. Long Term Disability, 534 F. App'x 340 (6th Cir. 2013).unpublished
- Perkins v. Gen. Motors, LLC, No. 4:16-cv-14465 (E.D. Mich. Jan. 26, 2022).
- Thomas Wenner v. Sun Life Assurance Co. of Canada, 482 F.3d 878 (6th Cir. 2007).published
- Becky Cooper v. Life Ins. Co. of North Am., 486 F.3d 157 (6th Cir. 2007).published
- Helfman v. GE Grp. Life Assurance Co., 573 F.3d 383 (6th Cir. 2009).published
- Thies v. Life Ins. Co. of North Am., 804 F. Supp. 2d 560 (W.D. Ky. 2011).published
- Bio-Med. Applications of Kentucky, Inc. v. Coal Exclusive Co., 782 F. Supp. 2d 438 (E.D. Ky. 2011).published
- Molodetskiy v. Nortel Networks Short-Term & Long-Term Disability Plan, 594 F. Supp. 2d 870 (M.D. Tenn. 2009).published
- Wenner v. Sun Life Assurance, No. 05-6740 (6th Cir. Apr. 12, 2007).published
- Leffew v. Ford Motor Co., 258 F. App'x 772 (6th Cir. 2007).unpublished
- Cannon v. PNC Fin. Servs. Grp., 645 F. App'x 344 (6th Cir. 2016).unpublished
- Freeman v. United States Dep't of Labor, 653 F. App'x 405 (6th Cir. 2016).unpublished
- Sorrell v. Comm'r of Soc. Sec., 656 F. App'x 162 (6th Cir. 2016).unpublished
- Jack Calhoun, Jr. v. Life Ins. Co. of North Am., 665 F. App'x 485 (6th Cir. 2016).unpublished
- Jesse Bruton v. Am. United Life Ins. Co., No. 19-3466 (6th Cir. Jan. 23, 2020).unpublished
- Bennetts v. AT & T Integrated Disability Serv. Ctr., 25 F. Supp. 3d 1018 (E.D. Mich. 2014).published
- Stephens v. Prudential Ins. Co. of Am., 122 F. Supp. 3d 692 (E.D. Mich. 2015).published
- Bishop v. Aetna Life Ins., 163 F. Supp. 3d 443 (E.D. Ky. 2016).published
- Carty v. Metro. Life Ins. Co., 224 F. Supp. 3d 606 (M.D. Tenn. 2016).published
- Zuke v. Am. Airlines, Inc., 644 F. App'x 649 (6th Cir. 2016).unpublished
- Tanner v. Nationwide Mut. Ins., 804 F. Supp. 2d 601 (S.D. Ohio 2011).published
- Acree v. Hartford Life & Accident Ins., 917 F. Supp. 2d 1296 (M.D. Ga. 2013).published
- Bailey v. United of Omaha Life Ins., 938 F. Supp. 2d 736 (W.D. Tenn. 2013).published
- Schnoor v. Walgreen Income Prot. Plan for Pharmacists & Registered Nurses, 968 F. Supp. 2d 869 (W.D. Mich. 2013).published
- James v. Liberty Life Assurance Co., 984 F. Supp. 2d 730 (W.D. Mich. 2013).published
- King v. Saul, No. 1:18-cv-07369 (N.D. Ill. Sept. 9, 2019).
- Bustetter v. CEVA Logistics U.S., Inc., No. 0:18-cv-00058 (E.D. Ky. Dec. 10, 2019).
- Bustetter v. Stand. Ins. Co., No. 0:18-cv-00001 (E.D. Ky. May 6, 2020).
- Rossiter v. Life Ins. Co. of North Am., 400 F. Supp. 3d 669 (N.D. Ohio 2019).published
- Geraci v. Hartford Life & Accident Ins. Co., No. 5:18-cv-02367 (N.D. Ohio Jan. 31, 2020).
- Loach v. Boilermaker-Blacksmith Nat'l Pension Trust (TV1), No. 1:19-cv-00351 (E.D. Tenn. Sept. 1, 2020).
- Linda Burge v. Repub. Engineered Prods., Inc., 432 F. App'x 539 (6th Cir. 2011).unpublished
- Susan Card v. Principal Life Ins. Co., 790 F. App'x 730 (6th Cir. 2019).unpublished
- Geiger v. Pfizer, Inc., 918 F. Supp. 2d 697 (S.D. Ohio 2013).published
At page 617 Reviewing administrative determination under arbitrary and capricious standard36 citing cases“deferential review is not no review.”
- Voltz v. Chrysler Grp. LLC-UAW Pension Plan, 63 F. Supp. 3d 770 (N.D. Ohio 2014).published Elliott, 473 F.3d at 620 (“Generally speaking, a plan may not reject summarily the opinions of a treating physician, but must instead give reasons for adopting an alternative opinion.”).
- Zenadocchio v. BAE Sys. Unfunded Welfare Benefit Plan, 936 F. Supp. 2d 868 (S.D. Ohio 2013).published Co., 437 Fed.Appx. 372, 379 (6th Cir.2011) (distinguishing from Rose , wherein “the claimant was surveilled as she conducted herself in a manner contrary to her claimed level of functionality”); Elliott, 473 F.3d at 618 (“[M]edieal data, w…
- Gragg v. UPS Pension Plan, No. 2:20-cv-05708 (S.D. Ohio Sept. 22, 2025). “deferential review is not no review.”
- Gragg v. UPS Pension Plan, No. 2:20-cv-05708 (S.D. Ohio Mar. 31, 2022). “deferential review is not no review.”
- Jalali v. UNUM Life Ins. Co. of Am., No. 2:20-cv-05071 (S.D. Ohio Mar. 28, 2022). “deferential review is not no review.”
- Miller v. Aetna Life Ins. Co., No. 2:19-cv-00500 (S.D. Ohio May 4, 2020). “deferential review is not no review.”
- Haning v. Hartford Life & Accident Ins., 140 F. Supp. 3d 654 (S.D. Ohio 2015).published “deferential review is not no review.”
- Robinette, No. 6:26-cv-00022 (E.D. Ky. Jan. 30, 2026).Co., 473 F.3d 613, 617 (6th Cir. 2006).
- Cheriese Johnson v. Reliance Stand. Life Ins. Co., 159 F.4th 1304 (11th Cir. 2025).publishedCo., 473 F.3d 613, 617 (6th Cir. 2006); Holmstrom v. Metro.
- Oakman v. Int'l United Auto. Aerospace & Agric. Workers, No. 1:23-cv-00026 (W.D. Ky. Aug. 6, 2025). Co., 473 F.3d 613, 617 (6th Cir. 2006) (quoting Glenn v. MetLife, 461 F.3d 660, 666 (6th Cir. 2006)).
Show 26 more citing cases
- Lechner v. Mut. of Omaha Life Ins. Co., No. 3:23-cv-00410 (W.D. Ky. Mar. 4, 2025).Co., 473 F.3d 613, 617 (6th Cir. 2006) (quoting Glenn v. MetLife, 461 F.3d 660, 666 (6th Cir. 2006)).
- Halleron v. Reliance Stand. Life Ins. Co., No. 3:22-cv-00633 (W.D. Ky. July 30, 2024).Co., 473 F.3d 613, 617 (6th Cir. 2006) (quoting Glenn v. MetLife, 461 F.3d 660, 666 (6th Cir. 2006), aff’d sub nom.
- Washington v. AT&T Umbrella Benefit Plan No. 3, No. 2:21-cv-11397 (E.D. Mich. Sept. 29, 2022).Co., 473 F.3d 613, 617 (6th Cir. 2006).
- Marselle v. UNUM Ins. Co. of Am., No. 3:19-cv-00464 (W.D. Ky. July 18, 2022). Co., 473 F.3d 613, 617 (6th Cir. 2006) (quotation omitted).
- Dana Campbell v. Hartford Life & Accident Ins. Co., No. 21-5651 (6th Cir. Mar. 3, 2022).unpublishedCo., 473 F.3d 613, 617 (6th Cir. 2006).
- Alvesteffer v. Howmet Aerospace, No. 1:20-cv-00703 (W.D. Mich. Feb. 22, 2022).Co., 473 F.3d 613, 617 (6th Cir. 2006).
- Morris v. Am. Elec. Power Long-Term Disability Plane, 399 F. App'x 978 (6th Cir. 2010).unpublished
- Violet Hogan v. Life Ins. Co. of North Am., 521 F. App'x 410 (6th Cir. 2013).unpublished
- Wagner v. Ciba Corp., 743 F. Supp. 2d 701 (S.D. Ohio 2010).published
- Thompson v. Transam Trucking, Inc., 750 F. Supp. 2d 871 (S.D. Ohio 2010).published
- Rabuck v. Hartford Life & Accident Ins. Co., 522 F. Supp. 2d 844 (W.D. Mich. 2007).published
- DELISLE v. Sun Life Assur. Co. of Canada, 636 F. Supp. 2d 561 (E.D. Mich. 2007).published
- Caudill v. Sears Transition Pay Plan, 714 F. Supp. 2d 728 (E.D. Mich. 2010).published
- Kyle Kennard v. Means Indus., Inc., 555 F. App'x 555 (6th Cir. 2014).unpublished
- Clayman v. Zurich Am. Ins. Co., 2013-Ohio-3866.published
- Rose v. Hartford Fin. Servs. Grp., Inc., 268 F. App'x 444 (6th Cir. 2008).unpublished
- Angela Smith v. Health Servs. of Coshocton, 314 F. App'x 848 (6th Cir. 2009).unpublished
- Klein v. Cent. States, 346 F. App'x 1 (6th Cir. 2009).unpublished
- Rose Moss v. Unum Life Ins. Co., 495 F. App'x 583 (6th Cir. 2012).unpublished
- Yulunda McAlister v. Liberty Life Assurance Co., 647 F. App'x 539 (6th Cir. 2016).unpublished
- Patti Okuno v. Reliance Stand. Life Ins. Co., 836 F.3d 600 (6th Cir. 2016).published
- Rebecca Filthaut v. AT&T Midwest Disability Benefit Plan, 710 F. App'x 676 (6th Cir. 2017).unpublished
- Watson v. W. & S. Fin. Grp. Flexible Benefits Plan, No. 2:18-cv-00066 (E.D. Ky. Aug. 16, 2019).
- Bustetter v. Stand. Ins. Co., No. 0:18-cv-00001 (E.D. Ky. Sept. 24, 2019).
- Cassidy v. Aetna Life Ins. Co., No. 6:19-cv-00201 (E.D. Ky. May 10, 2021).
- Yocum v. Aetna, No. 3:19-cv-00761 (W.D. Ky. Dec. 9, 2021).
At page 620 Evaluating physician opinions and arbitrary plan denials36 citing casesGenerally speaking, a plan may not reject summarily the opinions of a treating physician, but must instead give reasons for adopting an alternative opinion.
- Liggett v. Principal Fin. Grp., No. 2:22-cv-11183 (E.D. Mich. Jan. 23, 2025).(Generally speaking, a plan may not reject summarily the opinions of a treating physician, but must instead give reasons for adopting an alternative opinion.)
- Smith v. Reliance Stand. Life Ins. Co., No. 4:21-cv-00128 (W.D. Ky. Feb. 15, 2024). (Generally speaking, a plan may not reject summarily the opinions of a treating physician, but must instead give reasons for adopting an alternative opinion.)
- James Connelly v. Stand. Ins. Co., 663 F. App'x 414 (6th Cir. 2016).unpublished ([A] plan may not reject summarily the opinions of a treating physician, but must instead give reasons for adopting an alternative opinion.)
- Voltz v. Chrysler Grp. LLC-UAW Pension Plan, 63 F. Supp. 3d 770 (N.D. Ohio 2014).published (Generally speaking, a plan may not reject summarily the opinions of a treating physician, but must instead give reasons for adopting an alternative opinion.)
- Tate, JoAnn v. Long Term 506, No. 07-1022 (7th Cir. Sept. 19, 2008).published(‘Getting better,’ without more, does not equal ‘able to work.’)
- Miller v. Aetna Life Ins. Co., No. 2:19-cv-00500 (S.D. Ohio May 4, 2020). Although the Court's review is deferential, “it is not a rubber stamp for the administrator's determination.” Id. (“[D]eferential review is not no review.”).
- T. E. v. Anthem Blue Cross Blue Shield, 165 F.4th 971 (6th Cir. 2026).published Co., 473 F.3d 613, 620 (6th Cir. 2006).
- Galvin-Bliefernich v. First Unum Life Ins. Co., No. 1:20-cv-00266 (E.D. Tenn. Sept. 22, 2023).(finding denial of benefits arbitrary and capricious)
- Harmon v. Unum Life Ins. Co. of Am., No. 1:20-cv-00318 (E.D. Tenn. June 23, 2023). Co., 473 F.3d 613, 620 (6th Cir. 2006).
- Avery v. Sedgwick Claims Mgmt. Servs., Inc., No. 3:20-cv-11810 (E.D. Mich. Sept. 21, 2022).Life Ins., 473 F.3d 613, 620 (6th Cir. 2006)).
Show 26 more citing cases
- Marselle v. UNUM Ins. Co. of Am., No. 3:19-cv-00464 (W.D. Ky. July 18, 2022). Co., 473 F.3d 613, 617 (6th Cir. 2006) (quotation omitted).
- Alex Autran v. P&G Health & Long Term Disability, 27 F.4th 405 (6th Cir. 2022).publishedCo., 473 F.3d 613, 620 (6th Cir. 2006); Evans, 434 F.3d at 880 ).
- Rebecca Filthaut v. AT&T Midwest Disability Benefit Plan, 710 F. App'x 676 (6th Cir. 2017).unpublished
- McCandless v. Stand. Ins., 765 F. Supp. 2d 943 (E.D. Mich. 2011).published
- Gilewski v. Provident Life & Accident Ins. Co., 683 F. App'x 399 (6th Cir. 2017).unpublished
- Timothy O'Callaghan v. SPX Corp., 442 F. App'x 180 (6th Cir. 2011).unpublished
- Tate v. Long Term Disability Plan for Salaried Employees of Champion Int'l Corp. 506, 545 F.3d 555 (7th Cir. 2008).published
- Adams v. Hartford Life & Accident Ins., 694 F. Supp. 2d 1342 (M.D. Ga. 2010).published
- Butler v. United Healthcare of Tennessee, Inc., 764 F.3d 563 (6th Cir. 2014).published
- Raymond Shaw v. AT&T Umbrella Benefit Plan, 795 F.3d 538 (6th Cir. 2015).published
- Janice Curry v. Eaton Corp., 400 F. App'x 51 (6th Cir. 2010).unpublished
- Christina Hunter v. Life Ins. Co. of North Am., 437 F. App'x 372 (6th Cir. 2011).unpublished
- Cook v. Prudential Ins. Co. of Am., 494 F. App'x 599 (6th Cir. 2012).unpublished
- Vicki Koning v. United of Omaha Life Ins., 627 F. App'x 425 (6th Cir. 2015).unpublished
- Teresa Outward v. Eaton Corp. Disability, 808 F. App'x 296 (6th Cir. 2020).unpublished
- Lisa Holden v. Unum Life Ins. Co. of Am., No. 20-6318, 2021 WL 2836624 (6th Cir. July 8, 2021).unpublished
- Brainard v. Liberty Life Assurance Co., 173 F. Supp. 3d 482 (E.D. Ky. 2016).published
- Filthaut v. AT & T Midwest Disability Benefit Plan, 219 F. Supp. 3d 631 (E.D. Mich. 2016).published
- Caesar v. Hartford Life & Accident Ins., 464 F. App'x 431 (6th Cir. 2012).unpublished
- White v. Stand. Ins., 895 F. Supp. 2d 817 (E.D. Mich. 2012).published
- Greenwald v. Liberty Life Assurance Co., 932 F. Supp. 2d 1018 (D. Neb. 2013).published
- Vochaska v. Metro. Life Ins., 995 F. Supp. 2d 801 (W.D. Mich. 2014).published
- Withers v. United of Omaha Life Ins. Co., 527 F. Supp. 3d 918 (W.D. Ky. 2021).published
- Wehner v. Stand. Ins. Co., No. 2:18-cv-00982 (S.D. Ohio Nov. 15, 2019).
- Hoffman v. Nationwide Mut. Ins. Co. Short-Term Disability Plan, No. 2:19-cv-04360 (S.D. Ohio Sept. 22, 2021).
- Susan Card v. Principal Life Ins. Co., 790 F. App'x 730 (6th Cir. 2019).unpublished
At page 618 Determining reasoned judgment regarding work ability24 citing cases“medical data, without reasoning, cannot produce a logical judgment about a claimant's work ability.”
- Tranbarger v. Lincoln Life & Annuity Co. of New York, No. 2:20-cv-00945 (S.D. Ohio Mar. 29, 2022). (medical data, without reasoning, cannot produce a logical judgment about a claimant's work ability.)
- Zenadocchio v. BAE Sys. Unfunded Welfare Benefit Plan, 936 F. Supp. 2d 868 (S.D. Ohio 2013).published ([M]edieal data, without reasoning, cannot produce a logical judgment about a claimant’s work ability.)
- Haning v. Hartford Life & Accident Ins., 140 F. Supp. 3d 654 (S.D. Ohio 2015).published Although the Court’s review is deferential, “it is not a rubber stamp for the administrator’s determination.” Id. (“[D]eferential review is not no review.”).
- Parks v. Lincoln Nat'l Life Ins. Co., No. 4:22-cv-12814 (E.D. Mich. Mar. 21, 2024). Co., 473 F.3d 613, 618 (6th Cir. 2006)); see also Elliott, 473 F.3d at 618-19 (holding plan administrator did not rely on an application of evidence to occupational standard where it gave “no indication that [it] reasoned from [the claiman…
- Beth Jordan v. Reliance Stand. Life Ins. Co., No. 22-5234, 2023 WL 5322417 (6th Cir. Aug. 18, 2023).unpublishedCo., 473 F.3d 613, 618 (6th Cir. 2006).
- Kyle Kennard v. Means Indus., Inc., 555 F. App'x 555 (6th Cir. 2014).unpublished
- Bell v. Ameritech Sickness, 399 F. App'x 991 (6th Cir. 2010).unpublished
- James Neaton v. Hartford Life & Accident Ins. Co., 517 F. App'x 475 (6th Cir. 2013).unpublished
- Lamanna v. Special Agents Mut. Benefits Ass'n, 546 F. Supp. 2d 261 (W.D. Pa. 2008).published
- Richards v. Johnson & Johnson, 688 F. Supp. 2d 754 (E.D. Tenn. 2010).published
Show 13 more citing cases
- McCandless v. Stand. Ins., 765 F. Supp. 2d 943 (E.D. Mich. 2011).published
- Javery v. Lucent Tech., Inc. Long Term Disability Plan for Mgmt. or LBA Employees, 741 F.3d 686 (6th Cir. 2014).published
- McDonough v. Aetna Life Ins. Co., 783 F.3d 374 (1st Cir. 2015).published
- Gilewski v. Provident Life & Accident Ins. Co., 683 F. App'x 399 (6th Cir. 2017).unpublished
- Susan Card v. Principal Life Ins. Co., 17 F.4th 620 (6th Cir. 2021).published
- Brown v. Fed. Express Corp., 62 F. Supp. 3d 681 (W.D. Tenn. 2014).published
- Sapp v. Liberty Life Assurance Co., 210 F. Supp. 3d 846 (E.D. Va. 2016).published
- Foster v. Principal Life Ins. Co., 280 F. Supp. 3d 871 (E.D. La. 2017).published
- Greer v. Unum Life Ins. Co. Of Am., No. 3:17-cv-00615 (S.D. Miss. Sept. 30, 2021).
- Linda Burge v. Repub. Engineered Prods., Inc., 432 F. App'x 539 (6th Cir. 2011).unpublished
- Katherine Castor v. AT&T Umbrella Benefit Plan 3, No. 17-3400 (6th Cir. Mar. 26, 2018).unpublished
- Susan Card v. Principal Life Ins. Co., 790 F. App'x 730 (6th Cir. 2019).unpublished
- Bustetter v. Stand. Ins. Co., 529 F. Supp. 3d 693 (E.D. Ky. 2021).published
At page 619 Insufficiency of medical review to determine work capacity14 citing casesDr. Menotti’s review bears a striking resemblance to MetLife’s first denial letter.
- Thomas Judge v. Metro. Life Ins. Co., 710 F.3d 651 (6th Cir. 2013).published (Dr. Menotti’s review bears a striking resemblance to MetLife’s first denial letter.)
- Haning v. Hartford Life & Accident Ins., 140 F. Supp. 3d 654 (S.D. Ohio 2015).published Although the Court’s review is deferential, “it is not a rubber stamp for the administrator’s determination.” Id. (“[D]eferential review is not no review.”).
- Schwingle, Stephanie v. Hartford Life & Accident Ins. Co., No. 3:24-cv-00125 (W.D. Wis. Apr. 4, 2025).Co., 473 F.3d 613, 619 (6th Cir. 2006), Schwingle contends that Hartford’s decision was arbitrary and capricious because Hartford failed to consider whether she could perform the specific duties of her own job.
- O'Connell v. Hartford Life & Accident Ins. Co., No. 1:21-cv-10587 (D. Mass. Mar. 24, 2023).Co., 473 F.3d 613, 619-20 (6th Cir. 2006). 7 O’Connell also argues that Hartford’s lack of discussion of her childhood trauma as the origin of her anxiety is an abuse of discretion. [Dkt. 53 at 8].
- Watson v. W. & S. Fin. Grp. Flexible Benefits Plan, No. 2:18-cv-00066 (E.D. Ky. Aug. 16, 2019).
- Miller v. Am. Airlines, Inc., 632 F.3d 837 (3d Cir. 2011).published
- Schwarzwaelder v. Merrill Lynch & Co., 606 F. Supp. 2d 546 (W.D. Pa. 2009).published
- Hayden v. Martin Marietta Materials, Inc., 763 F.3d 598 (6th Cir. 2014).published
- Houston v. Unum Life Ins. Co. of Am., 246 F. App'x 293 (6th Cir. 2007).unpublished
- Donald Godmar v. Hewlett-Packard Co., 631 F. App'x 397 (6th Cir. 2015).unpublished
Show 4 more citing cases
- Doe v. Unum Life Ins. Co. of Am., 35 F. Supp. 3d 182 (D. Mass. 2014).published
- Mcmillan v. At&T Umbrella Benefit Plan No. 1, 161 F. Supp. 3d 1069 (N.D. Okla. 2016).published
- Ampe v. Prudential Ins. Co. of Am., No. 1:17-cv-11119 (D. Mass. Oct. 17, 2018).
- Linda Burge v. Repub. Engineered Prods., Inc., 432 F. App'x 539 (6th Cir. 2011).unpublished
[D]eferential review is not no review.
- Gragg v. UPS Pension Plan, No. 2:20-cv-05708 (S.D. Ohio Sept. 22, 2025). ([D]eferential review is not no review.)
- Gragg v. UPS Pension Plan, No. 2:20-cv-05708 (S.D. Ohio Mar. 31, 2022). ([D]eferential review is not no review.)
- Jalali v. UNUM Life Ins. Co. of Am., No. 2:20-cv-05071 (S.D. Ohio Mar. 28, 2022). ([D]eferential review is not no review.)
- Miller v. Aetna Life Ins. Co., No. 2:19-cv-00500 (S.D. Ohio May 4, 2020). ([D]eferential review is not no review.)
- Haning v. Hartford Life & Accident Ins., 140 F. Supp. 3d 654 (S.D. Ohio 2015).published ([D]eferential review is not no review.)
At page 623 Remanding for medical data regarding limitations1 citing case“we are not medical specialists and that judgment is not ours to make.”
- James Kitchen v. Catherine Bauman, 629 F. App'x 743 (6th Cir. 2015).unpublished “we are not medical specialists and that judgment is not ours to make.”
v.
METROPOLITAN LIFE INSURANCE COMPANY, Defendant-Appellee
This case presents the questions of whether an ERISA plan’s determination to deny benefits was arbitrary and capricious and, if it was, what remedy this court should order. Patricia Elliott submitted a claim for long-term disability benefits to the administrator of her employer’s employee benefit plan, Metropolitan Life (“MetLife”). MetLife denied Elliott’s claim. Thereafter, Elliott brought this ERISA action, based on the administrative record, against MetLife for wrongful denial of benefits under 29 U.S.C. § 1132(a)(1)(B). MetLife moved for judgment affirming its decision to deny bene[*615] fits and Elliott moved for reversal. Holding that MetLife’s determination to deny benefits was not “arbitrary and capricious,” the district court granted MetLife’s motion and denied Elliott’s motion. Elliott appealed to this court.
Because we conclude that MetLife’s decision was arbitrary and capricious, we vacate the judgment of the district court. The record does not support the conclusion that MetLife’s denial of Elliott’s claim was the result of a deliberative, principled reasoning process. We cannot say, however, that Elliott is clearly entitled to long-term disability benefits. Consequently, we remand to the district court with instructions to remand to Metlife for a full and fair review consistent with this opinion.
I
Elliott was injured severely in a car accident in 1989. At that time, she suffered significant fractures of her second and third cervical vertebrae. Soon after, she underwent stabilization and spinal surgery, which involved the placement of metallic wires in her neck. In 1993, Elliott began working for Great American Financial Resources and joined the company’s employee benefit plan, which MetLife administers.
In October 2002, Elliott began experiencing renewed pain related to the 1989 accident, including radiating shoulder pain, numbness, and burning sensations. She saw several physicians, beginning with Dr. Charles Kuntz of the University of Cincinnati’s Mayfield Clinic. In early 2003, Elliott began receiving short-term disability benefits, after Dr. Kuntz submitted a form to Great American certifying that she could not perform work of any kind. While on short-term disability in early 2003, Elliott visited several physicians and had numerous studies conducted. None could explain with precision why Elliott’s symptoms had reemerged.
In May 2003, Dr. Kuntz referred Elliott to Dr. Alex Schneider at Aring Neurology at the University of Cincinnati. Dr. Schneider conducted an initial electromyo-gram and found “no signs of motor or myelopathic symptoms.” However, he also made findings “consistent with a central cord-like syndrome.” In addition, Dr. Schneider wrote: “She is better than she was six months ago, but continued to have some chronic pain and anxiety related to this.” Dr. Schneider recommended, among other things, Elavil (a psychoactive prescription drug often prescribed for depression), a C-eollar (used to stabilize the neck), physical therapy, and a re-evaluation in three months.
Dr. Schneider saw Elliott again in August 2003. He made no significant new findings at that visit, except to note: “since starting the Elavil, she has done quite better [sic]. She states she is moving around better and her neck pain is better.” However, Dr. Schneider did report that she “has some weakness and numbness when she is up too long, particularly in her legs and feet.” Dr. Schneider increased her prescription, ordered more physical therapy, and recommended a return visit in three months, a date that coincides with Elliott’s most recent MRI.
In September 2003, Elliott began the long-term disability claims process. Her claim was denied on December 1, 2003, in a letter from MetLife. In the letter, Met-Life recounts the plan’s terms and restates technical medical terms from Elliott’s doctors’ reports. Then, without reasoning, the letter concludes: “The medial [sic] documentation does not support a condition of a severity that would prevent you from working.”
On December 9, 2003, Elliott sent a letter to MetLife appealing the decision.[*616] In the letter, Elliott wrote that her “condition has improved since the increase of [her] Elavil” prescription. She also wrote that “if I stand, sit, bend, walk, or sit up straight for too long, I require pain medication.” Describing her physical abilities, she wrote that “I have improved in motor skills since therapy and can tend to my daily needs without assistance. I can do some housework most days but am restricted to light duty (dusting, dishwasher, straightening, etc..[sic]).”
Elliott also included a letter from Dr. Schneider, dated December 9, 2003. In the letter, he described Elliott’s condition as “chronic weakness and numbness that is exacerbated when she is standing for any length of time.” Dr. Schneider also recounted Elliott’s last MRI, dated November 24, 2003, which showed “surgical changes along with mild to moderate dis-kogenic disease and degenerative changes.” There was “no clear syringo-myelia,” [1] although “metallic artifact limits the parenchymal visualization.” [2] Following that discussion, Dr. Schneider specified particular limitations on Elliott’s ability to work. He wrote:
It is my opinion that her work is limited due to her chronic pain syndrome and spinal cord injury that is exacerbated by spending any length of time on her feet or sitting in a single position for any length of time. She should not do any lifting. She should not be crouching into small spaces or doing any repetitive motion type of work. She should not do any work that requires reaching above her head. It is my opinion that her chronic neurologic condition causes her significant disability. This condition is chronic and will likely worsen in the future. Furthermore, she may require further surgical intervention as she develops further arthritic changes.
In response to Elliott’s appeal, MetLife engaged Dr. Robert Menotti to review Elliott’s file. The record indicates that Met-Life sent Elliott’s file to Dr. Menotti on February 25, 2004, and that he completed his review the next day. In the review, Dr. Menotti recounted Elliott’s medical history. Although Dr. Menotti conceded that Dr. Schneider’s statement “appears to be ... credible,” he nevertheless asserted that Elliott’s “condition improved over time with respect to her chronic pain,” especially with medication. Dr. Menotti then concluded that: “I am not left with the impression given the current level of documentation that the claimant appears medically unable to perform sedentary work based on the physical findings supplied by Dr. Schneider and by Dr. Kuntz.” Dr. Menotti was the first physician to mention the term “sedentary work,” which does not appear in the plan at issue.
Based on Dr. Menotti’s findings, Met-Life denied Elliott’s appeal. In its letter to Elliott, MetLife again recounted her medical history, including the latest reviews by Dr. Schneider and Dr. Menotti. Again without reasoning, MetLife then wrote: “There was no indication that your condition caused impairments which that would have prevented your [sic] from performing the duties of your job. Therefore, the original claim determination was appropriate.”
Following the denial of her appeal, Elliott brought an ERISA action against[*617] MetLife for wrongful denial of benefits under 29 U.S.C. § 1132(a)(1)(B). MetLife moved for judgment affirming its decision to deny benefits and Elliott moved for reversal. The district court granted Met-Life’s motion and denied Elliott’s motion. Elliott appealed.
II
We review de novo the decision of a district court granting judgment in an ERISA disability benefit action based on an administrative record. See Glenn v. Metro. Life Ins. Co., 461 F.3d 660, 665-66 (6th Cir.2006); Whitaker v. Hartford, Life & Accident Co., 404 F.3d 947, 949 (6th Cir.2005); Wilkins v. Baptist Healthcare Sys., Inc., 150 F.3d 609, 613 (6th Cir.1998). In addition, when a plan grants the administrator discretionary authority to interpret the terms of the plan and to determine benefits, courts will only reverse an administrator’s determination if it is “arbitrary and capricious.” Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 111-15, 109 S.Ct. 948, 103 L.Ed.2d 80 (1989); Glenn, 461 F.3d at 666; McDonald v. Western-Southern Life Ins. Co., 347 F.3d 161, 168 (6th Cir.2003). Because the Met-Life plan at issue in this case provides for discretion, we apply the “arbitrary and capricious” standard of review.
Although that standard is deferential, it is not a rubber stamp for the administrator’s determination. Jones v. Metro. Life Ins. Co., 385 F.3d 654, 661 (6th Cir.2004). In other words, “deferential review is not no review.” McDonald, 347 F.3d at 172 (citing Hess v. Hartford Life & Accident Ins. Co., 274 F.3d 456, 461 (7th Cir.2001)). Under that standard, we will uphold the administrator’s decision “if it is the result of a deliberate, principled reasoning process and if it is supported by substantial evidence.” Glenn, 461 F.3d at 666 (citing Baker v. United Mine Workers of Am. Health & Ret. Funds, 929 F.2d 1140, 1144 (6th Cir.1991)).
The question in any given disability case on “arbitrary and capricious” review is whether a plan can offer a reasoned explanation, based on the evidence, for its judgment that a claimant was not “disabled” within the plan’s terms. In pertinent part, the MetLife plan at issue here reads as follows: “ ‘Disabled’ or ‘Disability’ means that, due to sickness, pregnancy, or accidental injury, you are receiving Appropriate Care and Treatment from a Doctor on a continuing basis; and ... during your Elimination Period and the next 24 month period, you are unable to earn more than 80% of your Predisability Earnings or Indexed Predisability Earnings at your Own Occupation for any employer in your Local Economy.” The plan defines “Own Occupation” as: “the activity that you regularly perform and that serves as your source of income. It is not limited to the specific position you held with your Employer. It may be a similar activity that could be performed with your Employer or any other employer.”
Those terms are clear. To ascertain whether a claimant is disabled, Met-Life must determine whether the individual’s condition (sickness, pregnancy, or accidental injury) precludes her from performing her “Own Occupation.” Once MetLife makes that judgment, its determination is entitled to deference unless it is arbitrary and capricious. That is, if MetLife’s determination that an individual can perform her occupation “is the result of a deliberate, principled reasoning process and if it is supported by substantial evidence,” it will not be disturbed. Glenn, 461 F.3d at 666 (citing Baker, 929 F.2d at 1144).
[*618] III
A
We must therefore determine whether MetLife made a deliberate, principled, and reasoned decision that Elliott’s condition would not preclude her from performing her occupation. At the district court level, MetLife submitted an official description of the duties of an employee with Elliott’s former occupation as a Business Quality Analyst. [3] Elliott does not contest the use of that description here. [4] As such, we will treat Elliott’s official job description as giving the duties of her “Own Occupation” for analytical purposes.
A Business Quality Analyst’s essential responsibilities, inter alia, are to: (1) “Develop and prepare routine and non-routine reports needed from administration systems to effectively audit business activity”; (2) “Coordinate with other business areas to clarify/correct data”; (3) “Edit and review reports with management to ensure they meet business needs”; and (4) “Work with IT/Policy Administration support to drive effectiveness of reports needed.” To further those objectives, the company specified some of the skills that would be required, including proficiency in some computer software.
B
We must now ask whether MetLife made a reasoned judgment that Elliott’s medical condition allowed her to perform those or similar duties. Logically, MetLife could have made a reasoned judgment only if it relied on medical evidence that assessed Elliott’s physical ability to perform job-related tasks. McDonald, 347 F.3d at 172 (citing Quinn v. Blue Cross & Blue Shield Ass’n, 161 F.3d 472, 476 (7th Cir.1998)) (The plan “was under a duty to make a reasonable inquiry into the types of skills [the claimant] possesses and whether those skills may be used at another job.”). See also Osborne, 465 F.3d at 298 (affirming the denial of benefits, in part, because claimant “was once again able to perform the duties of his position”); Glenn, 461 F.3d at 669-70. Put differently, medical data, without reasoning, cannot produce a logical judgment about a claimant’s work ability. Despite the numerous medical evaluations that took place in this case, MetLife did not rely on an application of the relevant evidence to the occupational standard when it denied her claim initially and on internal appeal.
1
In its first denial letter, before having Elliott’s file reviewed by a physician consultant, MetLife merely recounted the technical contents of Elliott’s various medical evaluations. For example, MetLife wrote, “Per the April 22, 2003 office note from Dr. Kuntz the findings of the January 14, 2003 EMG revealed normal nerve conduction of the bilateral upper and lower[*619] limbs. Review of the CT of the cervical spine dated March 21, 2003, shows no evidence of significant central canal steno-sis.... It was suggested that you get a neurological consultation.” Then the letter says: “The medial [sic] documentation does not support a condition of a severity that would prevent you from working.”
We note that, in the first denial letter, MetLife states that it considered Elliott’s job description. Nevertheless, there is no indication that MetLife reasoned from Elliott’s condition to her ability to perform her occupation. There is no statement or discussion of Elliott’s occupational duties or her ability, or inability, to perform them. Instead, the denial letter is a mere recitation of medical terminology employed by various physicians in their diagnoses of Elliott’s condition, without any reasoning as to why those diagnoses would permit her to function in the workplace. A court’s decision that merely said “affirmed” or “reversed” could not be considered “reasoned.” Similarly, MetLife cannot be said to have given a reasoned denial of Elliott’s claim, initially.
2
Elliott appealed that initial determination, adding a letter from Dr. Schneider that related her condition to her work ability. In denying her appeal, MetLife relied on only one other new piece of evidence: the opinion of a physician consultant, Dr. Robert Menotti, who conducted a file-only review of Elliott’s claim. Because MetLife’s initial denial lacked a reasoned basis, MetLife’s second denial can only be characterized as “reasoned” if Dr. Menotti’s review provided an adequate basis to conclude that Elliott could perform her occupation despite her medical condition.
Dr. Menotti’s review bears a striking resemblance to MetLife’s first denial letter. In similar fashion, Dr. Menotti stated nearly verbatim from MetLife’s letter the technical findings related to Elliott’s condition. That recitation occupies more than half of Dr. Menotti’s two-page review. Cf. Kalish, 419 F.3d at 509 (rejecting as inadequate a report recounting six pages of medical history and engaging in only one page of analysis). In addition, Dr. Menotti presented no reasons for his conclusion that Elliott’s condition would not preclude her from working. He never discussed Elliott’s job duties, which implies that he did not conduct a reasoned evaluation of her condition to determine whether she could perform those duties.
To be sure, Dr. Menotti discussed Dr. Schneider’s conclusions about Elliott’s limited work ability. [5] In fact, he explicitly stated that Dr. Schneider’s conclusions “appear[ed] to be credible.” Yet Dr. Menotti offered no specific rebuttal to Dr. Schneider’s conclusions, nor did he opine as to how Elliott’s medical condition related to the demands of her job. Instead, Dr. Menotti concluded that earlier records demonstrated that Elliott’s condition “improved over time” and that her “chronic pain syndrome has responded to ... medi[*620] cation.” However, logically speaking, evidence of an improvement, without a starting or ending point, does not help answer the question of whether an individual can perform her occupation. “Getting better,” without more, does not equal “able to work.”
Moreover, based on his determination that Elliott was improving, Dr. Menotti stated a conclusion that is arguably on a different plane than the proper inquiry. He wrote: “I am not left with the impression given the current level of documentation that the claimant appears medically unable to perform sedentary work.” The term “sedentary work” appears nowhere in the plan’s terms. As we have noted, the proper inquiry is whether Elliott could perform her own occupation. Dr. Menotti never undertook such an inquiry.
In addition, Dr. Menotti was a physician consultant frequently employed by Met-Life. The Supreme Court has acknowledged “that physicians repeatedly retained by benefits plans may have an incentive to make a finding of ‘not disabled’ in order to save their employers money and to preserve their own consulting arrangements.” Black & Decker Disability Plan v. Nord, 538 U.S. 822, 832, 123 S.Ct. 1965, 155 L.Ed.2d 1034 (2003). See also Kalish, 419 F.3d at 507-08. Dr. Menotti’s conclusions have been questioned in at least three federal cases; in all of them, he was hired by MetLife. See White v. Airline Pilots Ass’n, 364 F.Supp.2d 747, 754 (N.D.Ill. 2005) (“The doctor’s language appears deliberately ambiguous and vague.... ”); Viglietta v. Metro. Life Ins. Co., 04 Civ. 3874, 2005 U.S. Dist. LEXIS 42924, at *32 (S.D.N.Y. Aug. 3, 2005) (“It is, however, highly unlikely that Dr. Menotti considered Plaintiffs revised job description ... ”); Smith v. Home Depot Welfare Benefits Plan, No. 8:04-cv-1924-T-23TBM, 2005 U.S. Dist. LEXIS 42916, at *36 (M.D.Fla. Nov. 17, 2005).
We express no opinion on whether Dr. Menotti was, in fact, influenced in this matter by his frequent employment by MetLife. It is clear, however, that he failed to conduct the appropriate inquiry. Dr. Menotti’s statements cannot form the basis for concluding that MetLife engaged in a deliberate, principled reasoning process in this case. Glenn, 461 F.3d at 666.
3
Nothing else in MetLife’s second denial provides any indication that Metlife engaged in a principled reasoning process. MetLife failed to offer any reason for rejecting Dr. Schneider’s conclusions about Elliott’s ability to work. Generally speaking, a plan may not reject summarily the opinions of a treating physician, but must instead give reasons for adopting an alternative opinion. Evans v. Unumprovident Corp., 434 F.3d 866, 877 (6th Cir.2006) (“[A] plan administrator may not arbitrarily disregard reliable medical evidence proffered by a claimant, including the opinions of a treating physician.”) (citing, inter alia, Black & Decker, 538 U.S. at 833, 123 S.Ct. 1965; McDonald, 347 F.3d at 163-66). Dr. Schneider’s letter indicated that Elliott would have trouble sitting for long periods of time and performing repetitive movements, both of which could well fall within her job description. Of course, MetLife need not defer automatically to the treating physician’s opinion. Black & Decker, 538 U.S. at 830-32, 123 S.Ct. 1965. However, that MetLife gave “greater weight” to a non-treating physician’s opinion for no apparent reason lends force to the conclusion that MetLife acted arbitrarily and capriciously. See Kalish, 419 F.3d at 508 (citing Calvert, 409 F.3d at[*621] 295). [6]
In addition, MetLife sought only a file review of Elliott’s claim, rather than a physical examination. To be sure, we rejected in Calvert a claimant’s assertion that a plan with authority to order additional medical tests was required to do so. 409 F.3d at 296. However, we also held that a plan’s decision to conduct a file-only review — “especially where the right to [conduct a physical examination] is specifically reserved in the plan — may, in some cases, raise questions about the thoroughness and accuracy of the benefits determination.” Ibid. Here, MetLife denied Elliott’s benefits based on evidence that simply is not analyzed in relation to her ability to perform her occupation. Although we continue to believe that plans generally are not obligated to order additional medical tests, in cases such as this, plans can assist themselves, claimants, and the courts by helping to produce evidence sufficient to support reasoned, principled benefits determinations. Cf. Glenn, 461 F.3d at 666.
We also note that MetLife may have been operating under a conflict of interest in this matter. The Supreme Court has recognized that an apparent conflict of interest exists when an ERISA plan both decides eligibility for benefits and pays those benefits. See Firestone, 489 U.S. at 115, 109 S.Ct. 948. In Glenn, we observed that “MetLife is authorized both to decide whether an employee is eligible for benefits and to pay those benefits. This dual function creates an apparent conflict of interest.” 461 F.3d at 666 (citations omitted). MetLife is under the same apparent conflict of interest here as it was in Glenn. Such a conflict, if shown to have impacted MetLife’s determination, would lend greater weight to the conclusion that MetLife’s determination was arbitrary and capricious.
We need not determine whether Met-Life’s self-interest played a role in its denial of Elliott’s claims. Regardless of the presence or absence of a conflict, Met-Life’s decision cannot withstand scrutiny. We cannot uphold an ERISA plan administrator’s determination if it is not the product of “a deliberate, principled reasoning process.” Glenn, 461 F.3d at 666. MetLife’s decision-making process was neither deliberate nor based on reasoning. As such, its determination in this matter was arbitrary and capricious.
IV
Now we are left to consider the remedy. In cases such as these, courts may either award benefits to the claimant or remand to the plan administrator. See Smith, 450 F.3d at 265 (“[W]e vacate the judgment of the district court and remand this case for entry of an order requiring CCC to conduct a full and fair review of Smith’s disability claim.”); Glenn, 461 F.3d at 675. See also Buffonge v. Prudential Ins. Co. of America, 426 F.3d 20, 31 (1st Cir.2005) (“There is no question that this court has the power to remand to the claims administrator; it also has the power, in appropriate cases, to award benefits to the disability claimant.”) (citing Cook v. Liberty Life Assur. Co., 320 F.3d 11, 24 (1st Cir.2003); Quinn v. Blue Cross and Blue Shield Ass’n, 161 F.3d 472, 477 (7th Cir.1998)). The question we must address is which remedy — retroactive benefits or[*622] remand to the administrator — is appropriate in this case.
The First Circuit recently addressed such a question. Buffonge, 426 F.3d at 31-32. In that case, the court noted that some courts have adopted the “categorical rule” that a “retroactive award is usually proper when [the] claimant had benefits and lost them,” while “remand is appropriate when a decision-maker fails to make adequate findings or fails to provide [] adequate reasoning.” Ibid, (citing Quinn, 161 F.3d at 477). The First Circuit declined to adopt such a categorical rule, holding instead that courts “must have considerable discretion to craft a remedy after finding a mistake in the denial of benefits.” Ibid, (citing Cook, 320 F.3d at 24).
In Buffonge, the court held that, where the “problem is with the integrity of [the plan’s] decision-making process,” rather than “that [a claimant] was denied benefits to which he was clearly entitled,” the appropriate remedy generally is remand to the plan administrator. Ibid. We agree with the First Circuit. Such a course is consistent with this court’s precedent and we adopt it here. [7] See Smith, 450 F.3d at 265 (“[W]e vacate the judgment of the district court and remand this case for entry of an order requiring CCC to conduct a full and fair review of Smith’s disability claim.”).
In this matter, we cannot say that Elliott is clearly entitled to benefits. Dr. Kuntz, at the time he certified that Elliott’s condition met the requirements for short-term disability, indicated she could not then perform work of any kind. However, in later reviews, Dr. Kuntz did not elaborate further on why Elliott’s condition precluded her from working. Also, while Dr. Schneider’s earlier reviews indicated some improvement with medication, his letter of December 9, 2003, indicates that Elliott’s condition would limit her ability to fulfill her job responsibilities. Just how much such limitations would affect her ability to work, however, we cannot say with any accuracy. For example, does Elliott have a sit-stand option at her job? When Dr. Schneider referred to repetitive movements, did he mean to include typing? If so, how much typing? Can Elliott dictate her reports, rather than type them? Even presuming that Dr. Schneider’s letter accurately states Elliott’s physical limitations, we simply cannot say whether those limitations would preclude her from working as a business quality analyst. And, as we have noted, Dr. Menotti’s review offers little support either way.
Thus, we believe that a remand to the district court with instructions to remand to MetLife for a full and fair inquiry is the proper remedy here. This course is contemplated both by our precedent and by ERISA law. Smith, 450 F.3d at 265. See also Black & Decker, 538 U.S. at 825, 123 S.Ct. 1965 (“ERISA and the Secretary of Labor’s regulations under the Act require ‘full and fair’ assessment of claims.”) (citing 29 U.S.C. § 1133 and 29 C.F.R. § 2560.503-1). Such a remedy will allow for a proper determination of whether, in the first instance, Elliott is entitled to long-term disability benefits. We are not[*623] medical specialists and that judgment is not ours to make. However, both MetLife and the claimant would be well advised to pursue appropriate medical data relating Elliott’s undeniable medical limitations to the demands of her occupation.
V
In this case, we were asked to address whether MetLife’s determination to deny long-term disability benefits to Patricia Elliott was arbitrary and capricious and, if it was, what remedy to order. As a result of the foregoing, we hold that MetLife’s determination was “arbitrary and capricious” for want of a deliberate, principled reasoning process. Glenn, 461 F.3d at 666. We also hold that the appropriate remedy is to remand to MetLife for a full and fair inquiry in accordance with this court’s precedent. Smith, 450 F.3d at 265. Accordingly, we vacate the district court’s judgment and remand the case for proceedings consistent with this opinion.
. Syringomyelia is “a slowly progressive syndrome of cavitation in the central segments of the spinal cord, generally in the cervical region.” Dorland's Illustrated Medical Dictionary 1841 (2003).
. This portion of Dr. Schneider's letter indicates that metallic artifacts from Elliott’s 1989 surgery limit his ability to see, using the test methods employed, the functional parts of the relevant portion of her spinal cord.
. The district judge thought that the job description meant that Elliott’s job was "sedentary in nature.” The court then concluded that MetLife’s denial of benefits, based on Dr. Menotti's conclusion that Elliott could perform "sedentary work,” was not arbitrary and capricious. That reasoning, also relied on by MetLife on appeal, was in error because it relies on a general notion of "sedentary” work rather than on the duties that Ms. Elliott’s occupation entailed. The latter inquiry is the proper one under the plan's terms.
. Indeed, as we recently held, MetLife’s determination of what duties Elliott’s job entailed would be entitled to review under the "arbitrary and capricious” standard of review. Osborne v. Hartford Life & Acc. Ins. Co., 465 F.3d 296, 298 (6th Cir.2006). In Osborne, we held that employing the dictionary to determine someone’s job duties was not "arbitrary and capricious.” Ibid. Certainly, under Osborne, MetLife's employment of the Elliott's official job description must also be entitled to deference.
. Dr. Menotti notes Dr. Schneider's findings that Elliott's work ability "is limited due to her chronic pain syndrome and spinal cord injury that is made worse by spending any length of time on her feet or sitting in a single position for any length of time.” Dr. Menotti also noted Dr. Schneider’s view that Elliott’s condition "is chronic and will likely worsen in the future and she may require further surgical intervention if she develops further arthritic changes.” Here, however, Dr. Menotti misquotes Dr. Schneider’s letter. Schneider wrote that Elliott may require surgery as she develops further arthritic changes, indicating that an ongoing process of arthritic degeneration was taking place. Dr. Menotti's letter changes "as” to "if,” which alters the meaning of the sentence by rendering further arthritic change only a possibility.
. Of course, as a general matter, we will not overturn a plan administrator's denial of benefits for choosing to rely on the opinion of one physician over that of another. McDonald, 347 F.3d at 169. However, that rule is not absolute, particularly where, as here, there is so little evidence of a process that reasons from the patient's condition to her work ability. Ibid. See also Glenn, 461 F.3d at 666-72.
. This remedy obviates the need to consider Elliott’s claim that the district court should have allowed further discovery. Smith, 450 F.3d at 265 ("On appeal, Smith argues that the district court erred when it denied additional discovery into CCC’s procedure. Because we are remanding this case for a full and fair review of Smith's disability claim, it is unnecessary for us to consider this claim on appeal.”). It should be noted, however, that while discovery is generally impermissible "in an ERISA action based on a review of the administrative record, an exception to that rule exists where a plaintiff seeks to pursue a decision-maker's bias.” See Calvert, 409 F.3d at 293 (citing Wilkins, 150 F.3d at 618).