Disability Benefits Claim-ERISA

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7^th Circuit Court of Appeals

Case Name: Donald Artz v. Hartford Life & Accident Insurance Company

Case No.: 23-2269

Officials: Scudder, Jackson-Akiwumi, and Pryor, Circuit Judges.

Focus: Disability Benefits Claim-ERISA

Artz, employed as an electric distribution controller at WEC Energy Group, retired due to multiple sclerosis (MS) and sought long-term disability benefits from a plan managed by Hartford Life and Accident Insurance Company. Hartford denied his claim, contending that Artz did not meet the plan’s definition of “disabled.” Artz initiated a lawsuit under the Employee Retirement Income Security Act, alleging that Hartford’s disability assessment was arbitrary and lacked reasonable explanation as it misinterpreted the plan’s terms.

The Eastern District of Wisconsin upheld the benefits denial at summary judgment. It determined that Artz had overly focused on the duties of his specific role at WEC rather than the “essential duties” of his job in the broader workplace context, as stipulated by the company’s plan. Additionally, the court emphasized the independent medical reviews commissioned by Hartford, which supported the conclusion that Artz’s MS did not hinder him from working a standard 40-hour week as a power-distribution engineer.

The Seventh Circuit found that Hartford had provided rational justifications for its decision, grounded in a fair interpretation of the plan and Artz’s medical records. The court concluded that the plan administrator had conducted a sufficient process, meeting the requirements of the Employee Retirement Income Security Act. While acknowledging the seriousness of Artz’s condition, the court observed that the evidence did not establish that the severity and persistence of his symptoms resulted in functional impairment as defined by the policy.

Affirmed.

Decided 05/06/24

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