Jackson v. The Hartford Financial Services Group, Inc.

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
LYNETTE JACKSON,
Plaintiff,
v.
THE HARTFORD FINANCIAL SERVICES
GROUP, INC.,
Defendant.
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No. 4:25-cv-01329-JAR
MEMORANDUM AND ORDER
Plaintiff Lynette Jackson sues The Hartford Financial Services Group for allegedly denying
and delaying her short- and long-term disability benefits. (ECF No. 1 at 1). She moves for leave
to proceed in forma pauperis, the appointment of counsel, leave to amend, and to compel a ruling.
(ECF Nos. 2–4, 6–8, 11–13). Because Jackson is unable to pay the costs associated with this action,
the Court grants her motion to proceed in forma pauperis. Nevertheless, for the reasons discussed
below, the Court dismisses this action without prejudice and denies all other pending motions.
I. Background
Jackson, a former employee of American Water, alleges that she first sought disability
benefits in 2019 due to unspecified health conditions. (ECF No. 1 at 1). She alleges that Hartford
engaged in bad faith and fraudulent practices by underpaying her short-term disability (“STD”)
benefits and erroneously claiming that she lacked long-term disability (“LTD”) coverage. Id. at
1–2. Jackson asserts that Hartford’s actions led to her termination from American Water in
November 2020, causing severe financial hardship, emotional distress, anxiety, and other mental
health issues. Id. at 2. She brings claims under the Employee Retirement Income Security Act
(“ERISA”), the Americans with Disabilities Act (“ADA”), the Rehabilitation Act, the Family
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and Medical Leave Act (“FMLA”), and various state laws. Id. at 1–2. She seeks $300,000,000 in
compensatory and punitive damages. Id. at 3.
Jackson previously pursued an action arising from the same alleged denial of disability
benefits. See Jackson v. Hartford Life and Accident Insurance Company, No. 4:24-cv-01366-
JAR (E.D. Mo. Oct. 11, 2024). The Court dismissed that action without prejudice after Jackson
failed to comply with a Court order. Id.
II. Standard
Under 28 U.S.C. § 1915(e)(2), the Court may dismiss a complaint filed in forma pauperis
if the action “(i) is frivolous or malicious; (ii) fails to state a claim on which relief may be granted;
or (iii) seeks monetary relief against a defendant who is immune from such relief.” A complaint is
frivolous if it lacks an arguable basis in law or fact. Martinez v. Turner, 977 F.2d 421, 423 (8th
Cir. 1992).
To state a claim for relief, a complaint must plead more than “legal conclusions” or
“[t]hreadbare recitals of the elements of a cause of action supported by mere conclusory
statements.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell Atl. Corp. v. Twombly, 550
U.S. 544, 555 (2007)). The plaintiff must allege facts that demonstrate a plausible claim for relief,
which requires more than a “mere possibility of misconduct.” Id. at 679. “A claim has facial
plausibility when the plaintiff pleads factual content that allows the Court to draw the reasonable
inference that the defendant is liable for the misconduct alleged.” Id. at 678 (citing Twombly, 550
U.S. at 556).
When reviewing a self-represented litigant’s complaint under § 1915, the Court accepts the
well-pleaded facts as true, White v. Clark, 750 F.2d 721, 722 (8th Cir. 1984) (per curiam), and
liberally construes the complaint, Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam); Haines
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v. Kerner, 404 U.S. 519, 520 (1972) (per curiam). Liberal construction means that, if the Court
can discern “the essence of an allegation,” it should construe the complaint in a way that permits
consideration of the claim within the proper legal framework. Solomon v. Petray, 795 F.3d 777,
787 (8th Cir. 2015) (quoting Stone v. Harry, 364 F.3d 912, 914 (8th Cir. 2004)). Even so, self-
represented plaintiffs must allege facts that, if true, state a claim for relief as a matter of law. Martin
v. Aubuchon, 623 F.2d 1282, 1286 (8th Cir. 1980). The Court does not assume unalleged facts,
Stone, 364 F.3d at 914–15, or excuse compliance with procedural rules. See McNeil v. United
States, 508 U.S. 106, 113 (1993).
III. Discussion
A. State-law claims
Jackson asserts state-law claims for bad faith and insurance fraud in relation to her
employee health plan. (ECF No. 1 at 2). It is well-established, however, that ERISA preempts
state-law tort and statutory claims—including bad faith and fraud—that “relate to” the
administration of an ERISA-governed plan. See, e.g., Kuhl v. Lincoln Nat. Health Plan of Kansas
City, Inc., 999 F.2d 298, 301 (8th Cir. 1993). Because Jackson’s claims for bad faith and fraud
arise directly from the administration of her employee health plan, they are preempted. Therefore,
the Court dismisses Jackson’s state-law claims.
B. ERISA claims
Jackson also invokes ERISA directly. (ECF No. 1 at 2). ERISA authorizes a participant or
beneficiary to sue “to recover benefits due to him under the terms of his plan, to enforce his rights
under the terms of the plan, or to clarify his rights to future benefits under the terms of the plan.”
29 U.S.C. § 1132(a)(1)(B). Liberally construed, Jackson’s complaint appears to challenge the
calculation and denial of disability benefits under an ERISA-governed plan. But Jackson does not
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identify a particular disability, impairment, or medical condition, nor does she allege any facts
describing functional limitations that would bring her condition within the plan’s definition of
disability.
Although Jackson need not plead medical evidence or a formal diagnosis at this stage, she
must allege sufficient factual matter to suggest entitlement to benefits under the plan. Without such
factual information, Jackson cannot plausibly establish that she had a qualifying disability or that
she was otherwise entitled to coverage. See Iqbal, 556 U.S. at 678–79. Jackson’s allegation that
she became “medically unable to work” (ECF No. 1 at 1) is a “naked assertion” devoid of “further
factual enhancement.” Id. Conclusory assertions that Hartford wrongly denied benefits, without
factual allegations plausibly suggesting entitlement to benefits under the terms of the plan, are
insufficient to state a claim under ERISA. Id. Accordingly, the Court dismisses Jackson’s ERISA
claims.
C. ADA and Rehabilitation Act claims
Jackson also asserts claims under the ADA and the Rehabilitation Act. Title I of the ADA
prohibits employment discrimination against qualified individuals with disabilities in the private
sector. 42 U.S.C. § 12112. To succeed under Title I of the ADA, an employee must demonstrate:
(1) a qualifying disability under the ADA, (2) the ability to perform essential job functions with or
without reasonable accommodation, and (3) an adverse employment action due to the disability.
McPherson v. O'Reilly Auto., Inc., 491 F.3d 726, 730 (8th Cir. 2007). Similarly, to state a claim
under § 504 of the Rehabilitation Act, a plaintiff must plausibly allege that (1) she is a qualified
individual with a disability; (2) she was excluded from participation in or denied the benefits of a
program or activity receiving federal financial assistance; and (3) the exclusion or denial occurred
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because of her disability. M.P. ex rel. K. & D.P. v. Indep. Sch. Dist. No. 721, New Prague, Minn.,
439 F.3d 865, 867 (8th Cir. 2006).
Liberally construed, Jackson’s allegations—that her disability claims were denied and that
she was treated unfairly as a result—might suffice to plausibly allege disability discrimination by
her former employer. But Jackson does not sue her former employer in this action. Instead, she
brings suit only against Hartford, the insurer. Jackson does not allege that Hartford discriminated
against her on the basis of her disability, only that American Water terminated her employment on
that basis. (ECF No. 1 at 2). The Court therefore dismisses Jackson’s ADA and Rehabilitation Act
claims.
D. FMLA claim
Jackson alleges that Hartford interfered with her FMLA rights. The FMLA makes it
unlawful for an “employer” to “interfere with, restrain, or deny [one’s] exercise of or the attempt
to exercise” his or her rights under the Act. 29 U.S.C. § 2615(a)(1). It also prohibits discrimination
against “any individual for opposing any practice made unlawful” under the Act. 29 U.S.C. §
2615(a)(2).
As with her ADA and Rehabilitation Act claims, Jackson’s FMLA claim fails because she
does not allege that Hartford was her employer. Without such an allegation, the Court cannot
reasonably infer that Hartford violated the FMLA. See Iqbal, 556 U.S. at 678–79; McNeil, 508
U.S. at 113. Accordingly, the Court dismisses Jackson’s FMLA claim.
E. Motion to amend
Jackson moves for leave to amend her complaint to add claims for “fraud upon the court,”
denial of access to the courts, and alleged attorney and clerk misconduct. (ECF No. 8). She attaches
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a proposed amended complaint setting forth additional factual allegations related to prior litigation
and alleged irregularities in court proceedings. (ECF No. 8-1).
Although Federal Rule of Civil Procedure 15(a)(2) provides that courts should freely give
leave to amend when justice so requires, a court may deny leave where amendment would be futile.
See Zutz v. Nelson, 601 F.3d 842, 850–51 (8th Cir. 2010). An amendment is futile if the proposed
claims would not survive review under Rule 12(b)(6). Id. at 852.
The Court has reviewed Jackson’s proposed amendment. The additional allegations
concern alleged misconduct in prior proceedings, purported misuse of case numbers, and denial of
access to courts. Even accepting those allegations as true, they do not state a plausible claim for
relief against Hartford in this action. The proposed amendment does not allege facts curing the
deficiencies identified above with respect to Jackson’s ERISA, ADA, Rehabilitation Act, or
FMLA claims. Nor does it establish an independent cause of action against Hartford arising from
the alleged irregularities in other proceedings.
Because the proposed amendment would not state a cognizable claim against Hartford and
would not remedy the pleading deficiencies in the original complaint, amendment would be futile.
See Zutz, 601 F.3d at 852. The Court therefore denies Jackson’s motion for leave to amend. (ECF
No. 8).
IV. Conclusion
For the foregoing reasons, the Court grants Jackson’s motion to proceed in forma pauperis
and dismisses this action for failure to state a plausible claim to relief under 28 U.S.C.
§ 1915(e)(2)(B)(ii). The Court denies all other pending motions.
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Accordingly,
IT IS HEREBY ORDERED that Jackson’s motion to proceed in forma pauperis (ECF
No. 2) is GRANTED.
IT IS FURTHER ORDERED that Jackson’s motion to amend (ECF No. 8) is DENIED.
IT IS FURTHER ORDERED that this action is DISMISSED without prejudice.
IT IS FURTHER ORDERED that all other pending motions (ECF Nos. 3, 4, 6, 7, 11–
13) are DENIED as moot.
A separate Order of Dismissal accompanies this Memorandum and Order.
Dated this 9th day of February 2026.
JOHN A. ROSS
UNITED STATES DISTRICT JUDGE
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