As a daughter of a disabled veteran, I’m unhappy to report this week’s notable decision, Martinez v. Sun Life Assurance Co. of Canada, No. 18-2127, __F.3d__, 2020 WL 415145 (1st Cir. Jan. 27, 2020). The First Circuit affirmed the district court’s determination that Sun Life properly interpreted the language of a disability plan, which it funded, to permit the offset of service-connected disability compensation (“Veterans’ Benefits”) against employer-sponsored long-term disability (“LTD”) benefits. In so doing, the Court determined that Veterans’ Benefits are unambiguously “Other Income Benefits” covered by the Plan’s offset provision and that the offset is not a violation of the Uniformed Services Employment and Reemployment Rights Act (“USERRA”).
Continue Reading First Circuit Gives Sun Life Green Light to Offset Veterans’ Benefits against Long Term Disability Benefits
Court Holds MetLife Erred in Applying Pre-existing Condition Limitation to Long-Term Disability Claim Following Workplace Injury
Good morning, ERISA Watchers! This week we want to highlight a district court decision involving a pre-existing condition limitation in a long-term disability (“LTD”) policy, Meche v. Metropolitan Life Insurance Co., No. CV 18-3995, 2020 WL 133284 (E.D. La. Jan. 13, 2020). In this case, MetLife denied Meche’s claim for LTD benefits following a lumbar spine injury he experienced at work. He filed a claim for LTD benefits with MetLife since the injury necessitated his immediate cessation of work activities. The LTD policy contained the following limitation:
Pre-existing Condition means a Sickness or accidental injury for which You:
• received medical treatment, consultation, care, or services; or
• took prescribed medication or had medications prescribed;
in the 12 months before Your insurance, or any increase in the amount of insurance, under this certificate takes effect.
Continue Reading Court Holds MetLife Erred in Applying Pre-existing Condition Limitation to Long-Term Disability Claim Following Workplace Injury
Eighth Circuit Affirms Dismissal of Complaint Seeking Continued Long-Term Disability Benefits Based on Physical Disability
This week’s notable decision is Miller v. Hartford Life & Accident Ins. Co., No. 19-1096, __F.3d__, 2019 WL 6834049 (8th Cir. Dec. 16, 2019), a case highlighting the difficulty of establishing a “physical” disability claim when the symptoms are psychiatric in nature. Plaintiff Diane Miller filed an action against Hartford Life & Accident Insurance Company (“Hartford”) when it terminated her claim for long term disability benefits based on the exhaustion of benefits owed due to a mental illness, and the lack of evidence of a disabling physical condition which would justify further benefit payments. The district court granted Hartford’s motion to dismiss, finding that Hartford’s decision was supported by substantial evidence. The Eighth Circuit Court of Appeals affirmed.
Plaintiff argued that the dismissal of her complaint was erroneous for several reasons, including that there was insufficient evidence of improvement in her condition and that Hartford failed to consider the potential medications side effects and the future risk of additional psychotic episodes. The court explained that these arguments fail to consider the primary reason for Hartford’s benefit termination: the fact that the record did not support a finding of a physical disability.
Continue Reading Eighth Circuit Affirms Dismissal of Complaint Seeking Continued Long-Term Disability Benefits Based on Physical Disability