"A 'benefit determination on review' must finally decide the claimant's benefits within 45 days, assuming the absence of special circumstances that require an extension," Walker wrote for the panel. "By the 46th day after his appeal, Hartford had not determined McQuillin's benefits nor extended its review time. So, McQuillin was deemed to have exhausted his plan remedies and could bring suit in federal court."

The panel found that a valid "benefit determination on review" must determine whether the claimant is entitled to benefits, rejecting Hartford's argument that non-final decisions constitute benefit determinations.

The U.S. Secretary of Labor and the American Council of Life Insurers each filed amicus briefs in the case, with the DOL supporting McQuillan and ACLI supporting Hartford.

The labor department's brief, signed by Senior Trial Attorney Marcia Bove of the department solicitor's Plan Benefits Security Division, held that the district court's interpretation could lead to an outcome "thwarting ERISA's purpose" of providing access to the federal courts.

"Enforcement of the 45-day time limit imposed by the regulation for review of disability claim denials is critical to protecting claimants who need the replacement income that disability benefits provide," Bove wrote. "The district court's interpretation of the regulation, if upheld, risks nullifying those requirements."

The American Council of Life Insurers was represented by attorneys with Ogletree, Deakins, Nash, Smoak & Stewart, who argued in their brief that Hartford's process was consistent with ERISA.

Claim administrators should be able to "render complete and accurate claim decisions based on a full evidentiary record," they argued.

"Claim administrators have no desire or incentive to drag out the disability claim process which is already complex and time consuming nor have Plaintiff or the Department proffered any support for such an outcome," they wrote.