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].
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Post 4846
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See the full video at https://lnkd.in/g8rh3JBX and https://lnkd.in/gmkdy-9C, In United States Of America v. Thomas Addaquay, Nos. 25-10609, 25-10611, United States Court of Appeals, Eleventh Circuit (September 9, 2026) the Eleventh Circuit affirmed all challenged convictions, the 150-month aggregate sentence, and the challenged $4,123,474.55 restitution award.
FACTS
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Post 5489
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Post 4855
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Posted on October 1, 2026 by Barry Zalma
From October 1, 1979 – 2026
Post 4854
Read the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/09/ZIFL-10-01-2026.pdf Forty seven years ago today I left the world of the employed and became an entrepreneur by opening my own law firm. The law practice was incorporated shortly thereafter as Barry Zalma, Inc.
When I opened for business on October 1, 1979, I had no clients and no certainty that I would have any in the future. I had borrowed money from the bank to carry me through the first six months and was concerned about my ability to pay the loan with my third child about to be born.
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Post 4854
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Jeffrey Wayne Phillips had contracted with Creative Website Studios and SR Telecommunications for website and hosting services. He alleged that defendants repeatedly billed him for hosting periods he had already paid for and later took down his website. Phillips claimed the outage prevented him from bidding on U.S. government security contracts and sought roughly $300 million in consequential damages.
LAW
Under North Carolina law, fraud requires a false material representation or concealment, intent and effect of deception, resulting damage, and reasonable reliance. Obtaining property by false pretenses similarly requires an ...
