In Griffin v. Hartford Life & Acc. Ins. Co., 898 F.3d 371 (4th Cir. 2018), the Fourth Circuit addressed the issue of whether a related company of an entity that enjoyed the abuse of discretion standard also was entitled to the same deference.
The plaintiff's claim, which is somewhat novel, is that while Hartford Life & Accident Insurance Company retained discretionary authority, and, therefore, a discretionary standard of review of the plaintiff's benefit determination, the adjusters who decided the claim were paid by a subsidiary of the Hartford group of companies--namely, Hartford Fire Insurance Company. The plaintiff reasoned that because Hartford Fire was a separate entity from Hartford Life, the abuse of discretion standard did not apply. The district court and the Fourth Circuit ruled against the plaintiff on this point, and upheld the claim denial. The Fourth Circuit relied on undisputed evidence that the correspondence with plaintiff concerning his claim...
