Disability Benefit Claims

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Good morning, ERISA Watchers!  It was quite the week for ERISA decisions and it was difficult to pick just one notable decision, but the winner is Griffin v. Hartford Life & Accident Ins. Co., No. 17-1251, __F.3d__, 2018 WL 3624872 (4th Cir. July 31, 2018).  The Fourth Circuit affirmed the district court’s determination that abuse of discretion, rather than de novo, applies to Hartford’s decision terminating long term disability benefits and its conclusion that Plaintiff failed to show that Hartford Life’s decision was unreasonable. 

On the standard of review, Griffin contended that the relevant plan documents gave Hartford Life full discretion to determine eligibility for benefits.  However, the decision to terminate his benefits was made by Hartford Fire Insurance Company, which is an affiliated corporation in The Hartford group of companies.  This was based on the W-2 tax forms for the Hartford employees who made the termination decision which showed that they were employees of Hartford Fire. 
Continue Reading Fourth Circuit Rules for Hartford Life In Long Term Disability Denial

Good morning, ERISA Watchers!  Today’s report is lighter than usual due to the extra mid-week report sent out this past Wednesday.  My radar has not picked up another notable Circuit decision since then but today I want to highlight a district court opinion, Paquin v. The Prudential Insurance Company of America, 2018 WL 3586397 (D. Colo. July 26, 2018), because it involves a claimant prevailing on a long-term disability claim and those are my favorite kinds of cases!

In Paquin, the plaintiff contracted encephalitis from a mosquito infected by the West Nile virus and sustained brain damage and cognitive difficulties that interfered with his job as a Business Development Director.  Prudential paid Paquin both short term disability benefits and long term disability benefits, until he attempted, unsuccessfully, to return to work for a trial period in 2004. 
Continue Reading Court Reverses Prudential’s Termination of Long Term Disability Benefits for Claimant Disabled by West Nile Virus Exposure

Good morning, ERISA Watchers!  Today’s newsletter is ERISA Watch-lite since I just returned from Hawaii this weekend and am slowly readjusting to life on the mainland.  Below are a small handful of the appellate decisions that came out over the past couple of weeks.  A case I want to highlight is one you may have already read by now, but since it’s SO good, it is this week’s notable decision – Nichols v. Reliance Standard Life Ins. Co., No. 3:17-CV-42-CWR-FKB, 2018 WL 3213618 (S.D. Miss. June 29, 2018).

In Nichols, Judge Carlton Reeves found that Reliance Standard Insurance Company abused its discretion in denying Nichols’ claim for long-term disability benefits.  Though it’s a tale as old as time, what makes this decision stand out is the Court’s analysis of Reliance Standard’s “decades-long pattern of arbitrary claim denials and other misdeeds.” 
Continue Reading Court Examines Two Decades of Reliance Standard Life Insurance Company’s Abuse of Discretion in Disability Benefit Claims