After first determining that Sedgwick Claims Management Services was afforded discretionary authority by Hewlett-Packard to make determinations regarding a claimant’s eligibility for benefits under the plan, U.S. District Judge Melinda Harmon of the U.S. District Court for the Southern District of Texas, reviewed Sedgwick’s denial of Curley’s long-term benefits for abuse of discretion, saying: “Our review of the administrator’s decision need not be particularly complex or technical; it need only assure that the administrator’s decision fall somewhere on a continuum of reasonableness–even if on the low end.”
Harmon said Sedgwick presented substantial evidence from a number of physicians to support its decision to deny Charlene Curley disability benefits. Based on the available medical documentation, Sedgwick reasonably concluded that Curley was not totally disabled under the plan, and thus its decision was not an abuse of discretion.
The opinion noted that under the plan, “total disability,” means that “following the initial twenty-four month period after onset of the injury or sickness the Participant is continuously unable to perform any occupation for which he is or may become qualified by reason of his education, training, or experience.”
Curley worked for Hewlett-Packard and its predecessor companies as a business planning manager and a project manager for approximately seventeen years from 1988 to 2005. Her job demanded substantial use of the telephone and computer, requiring her to sit in the same position for long periods. Curley alleges she became disabled from her business planning manager position in October 2004, due to carpal tunnel syndrome, cervicalgia, cervical radiculopathy, depression, and chronic pain, including upper extremity pain, left brachiolexus injury, left hand numbness, and chronic neck, shoulder, and back pain.
After carpal tunnel surgery and a surgery to repair the rotator cuff in her right shoulder, Curley worked sporadically, eventually returning on a part-time basis. However, Hewlett-Packard determined the position needed someone full-time and terminated her. Curley then received twenty-four months of long-term disability benefits under the plan. On September 26, 2006, Curley’s twenty-four month’s period of long-term disability benefits expired, and Sedgwick reassessed her medical condition, then renewed Curley’s disability benefits.
In May 2008, Sedgwick initiated another periodic review of Curley’s condition and asked her to see an orthopedic surgeon. The doctor did not determine Curley was incapable of working, but recommended specific restrictions for her working environment, including “no frequent overhead work, no prolonged repetitive wrist motions, i.e., typing or computer, and no prolonged standing or sitting greater than 1-2 hours without stretching and short rest.”
Following the doctor’s evaluation, Sedgwick concluded that Curley was not “totally disabled from any occupation” and terminated her long-term disability benefits.The case is Curley v. Sedgwick Claims Management Services Inc., S.D. Tex., No. 4:10-cv-00117.