Background
Amanda Martin, a former employee of the Federal Reserve Bank of Cleveland, sought long-term disability benefits under the Bank’s plan after taking leave due to symptoms of long-haul COVID-19. The plan administrator, Matrix Absence Management, Inc., denied her claim, concluding she was not totally disabled as of her last day of work. Martin sued for breach of contract and breach of fiduciary duty, seeking discovery outside the administrative record. The district court denied her discovery requests and granted judgment on the administrative record for the defendants.
The court’s reasoning
The Sixth Circuit applied New York contract law because the plan was not governed by ERISA. Under this standard, the court could set aside the administrator’s decision only if it was made in bad faith, was arbitrary, or resulted from fraud. The court found the district court properly limited review to the administrative record, as Martin failed to allege a sufficient conflict of interest or procedural defect to warrant discovery. Regarding the merits, the court held that Matrix provided a reasoned explanation for its denial by relying on independent medical opinions and evidence of Martin’s ability to work and symptom improvement around the time she took leave.
Your client’s working through and until April 13, 2022, demonstrated, in and of itself, that they were fully capable of working on a full-time, consistent basis, and not Totally Disabled by definition.
Martin v. Fed. Rsrv. Bank of Cleveland, et al., No. 25-3518, slip op. at 7 (6th Cir. May 7, 2026)
What it means going forward
The ruling reinforces that non-ERISA disability plans with discretionary authority vesting in an administrator are subject to an arbitrary-and-capricious standard of review under applicable state law, limiting judicial inquiry to the administrative record absent specific allegations of bias or procedural irregularity.