District Judge Kenneth M. Karas


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Shortly after she began working for Pfizer in 2002, Chang experienced a severe sinus infection. Terminated in 2009, Chang was rehired in April 2011. During her employment, Chang participated in Pfizer’s short-term disability (STD) and long-term disability (LTD) plans. On March 4, 2014 she was discovered struggling to breathe and rushed to medical. She was granted STD benefits after diagnosis of hypersensitive airway disease with bronchitis and asthma. STD benefits were terminated on March 12, 2014. Her appeal was denied for insufficient medical documentation of continuing treatment. Subsequent requests for LTD benefits and the ability to work for home were denied. Losing health insurance, Chang was rendered homeless. Her lawsuit charging Pfizer with contract breach and related causes of action argued that by impermissibly denying her STD benefits, Pfizer prevented her from obtaining LTD benefits. Denying Chang remand, the court dismissed her lawsuit to the extent it sought benefits and/or damages under the LTD plan. Her claims “implicated coverage and benefits established by the terms of [an] ERISA benefit plan,” and there was no independent legal duty for Pfizer to provide Chang with LTD benefits.