ERISA Gives the Insurer Discretion to Make Benefits Decision
Read the full article at https://lnkd.in/gSnUT5Pp and at https://zalma.com/blog plus more than 4300 posts.
Carol Stewart sued Hartford Insurance Company to obtain two insurance benefits that she believes it owes her: longterm disability payments and a waiver of life-insurance premiums.
In Carol H. Stewart v. Hartford Life And Accident Insurance Company, No. 21-11919, United States Court of Appeals, Eleventh Circuit (August 10, 2022) the Eleventh Circuit found itself compelled to follow the statute rather than its own conclusions regarding the availability of coverage to Ms. Stewart.
Hartford contended that although she was insured it concluded that she was ineligible for the benefits she sought.
Hartford’s policy, in accordance with the statutory ERISA statute indisputably granted it discretion to make benefits determinations.
In 2010, Burr Forman cancelled its policy with Sun Life and switched the administration of its ERISA health plan over to Hartford Insurance.
Hartford determined that Stewart wasn’t “Disabled” within the meaning of its policy and that she therefore had to pay life-insurance premiums.
Stewart sued only to have the district court grant Hartford’s summary judgment.
ANALYSIS
Since the Burr Forman’s plan vested Hartford with discretion in reviewing claims Did Hartford’s policy vest it with discretion when reviewing benefits claims.
The policy expressly states that Hartford has “full discretion and authority to determine eligibility for benefits and to construe and interpret all terms and provisions of The Policy.”
The Eleventh Circuit affirmed the district court’s decision rejecting Stewart’s claim to disability benefits.
Did Hartford Correctly Denied Stewart A Waiver Of Life-Insurance Premiums.
It did. The record shows that Stewart could do "any" work. The word “any,” expresses a lack of restriction. Because Hartford’s interpretation was not wrong, the Eleventh Circuit ended the inquiry at Step 1 and affirm the decision.
To summarize, Stewart was not entitled to disability payments because Hartford’s interpretation of the disability exclusion was reasonable, and its conflict of interest didn’t lead it to make an arbitrary or capricious decision.
ZALMA OPINION
ERISA is a special statute that allows employers to create a thorough and relatively inexpensive series of benefits for its employees. The result may seem unfair but the decision fits the requirements of the statute.
(c) 2022 Barry Zalma & ClaimSchool, Inc.
Barry Zalma, Esq., is available at http://www.zalma.com and [email protected].
Subscribe and receive videos limited to subscribers of Excellence in Claims Handling at locals.com https://lnkd.in/gfFKUaTf.
Subscribe to Excellence in Claims Handling at https://lnkd.in/gNm9EWKJ. Go to the Insurance Claims Library – https://lnkd.in/gKCTg53
Sponsor
We are, so far, 80% funded for April. I am matching donations dollar for dollar this month. Thanks to everyone who helped out. 🥰
Xephula monthly operating expenses for 2024 - Server: $143/month - Backup Software: $6/month - Object Storage: $6/month - SMTP Service: $10/month - Stripe Processing Fees: ~$10/month - Total: $175/month
Zoeken
Sponsor
Categorieën
- Art
- Causes
- Crafts
- Crime
- Dance
- Drinks
- Film
- Finance
- Fitness
- Food
- Spellen
- Gardening
- Health
- Home
- Literature
- Music
- Networking
- Paranormal
- Other
- Politics
- History
- Party
- Science
- Religion
- Shopping
- Sports
- SyFy
- Politically Incorrect
- Philosophy
- Theater
- Technology
- Wellness
Read More
Trump's approval at 53%
The Rasmussen Reports daily Presidential Tracking Poll for Wednesday shows that 53% of Likely U....
UNTIMELY SUIT DISMISSED
Judgment in Favor of Insurer Because of Plaintiff’s Sloth
Read the full article at...
More Construction Defects
Multiple Construction Defects
Read the full article at...
The Legend of Rittenhouse
View the source...
Pretext: Some cockwad named Jacob Blake – a convicted rapist and...