by Steve Fields | August 10th, 2022
August 10, 2022, U.S. Court of Appeals – 11th Circuit – 43 F.4th 1251
Stewart’s claim for Long Term Disability benefits and waiver of life-insurance premiums was denied by Hartford. Hartford denied the claim on the basis that Stewart was ineligible for Long Term Disability benefits based on a policy exclusion and that she was not disabled under the terms of the plan.
Stewart’s policy contained an exclusion that a member of her law firm was ineligible for disability insurance payments if she was receiving benefits for a disability under a prior disability plan that was sponsored by her Employer and terminated before the effective date of the policy. Hartford also determined that Stewart was not disabled under the definition of the life insurance policy, so she was not entitled to a waiver of those premiums.
Although the Court of Appeals indicated that Stewart may have a better reading of the policy than the Hartford, they nonetheless upheld Hartford’s denial of her Long Term Disability claim, granting deference to the Hartford and finding that Hartford did not abuse their discretion in their reading and application of the policy. The Court of Appeals also found that the record reasonably supported Hartford’s determination that she could perform less demanding sedentary work and was therefore not entitled to the life insurance premium waiver benefit.
This case highlights the harsh reality of the abuse of discretion standard of review. The Court of Appeals in this case seems to prefer Stewart’s position and argument on her claim for Long Term Disability benefits, but they are required to give deference to the Hartford’s decision because of the way the policy was written. Our attorneys are standing by to help assist you with your Long Term Disability claims that often involve these complex and nuanced interpretation issues.
