How Far Must An Insurer Go to Provide Long Term Disability Benefits?
In an interesting fact pattern, the court in Cochran v. Hartford Life and Acc. Ins. Co., 2010 WL 259047 (E.D.Mich. Jan. 20, 2010), complimented Hartford Life and Accident Insurance Company’s handling of a claim for long term disability benefits, in which the court stated, “It is difficult to imagine what more Hartford could have done for Plaintiff, short of actually securing him employment, which Hartford clearly had no legal obligation to do.”
In this matter, Plaintiff had fractured an ankle in a non-work related automobile accident, for which he was also cited for driving under the influence. While receiving long term disability benefits from Hartford Life, plaintiff elected to become trained as a tattoo artist, and Hartford Life paid for the vocational training — at a cost of $6,500. Plaintiff remained on disability benefits for two years following his accident.
Notwithstanding plaintiff’s excellent performance in his tattoo apprenticeship and his personal election to request vocational training in that occupation, plaintiff later brought an ERISA claim based on Hartford Life’s decision to terminate disability benefits under an “any occupation” standard.
The United States District Court for the Eastern District of Michigan granted Hartford Life’s Motion for Entry of Judgment, and concluded that the relief or assistance the plaintiff was seeking was not long term disability benefits, but more in the nature of unemployment benefits:
Hartford made a reasoned decision, based on the entire Administrative Record, that Plaintiff was capable of performing, based upon his functional limitations as described by his own treating physician, several jobs that it identified in the relevant geographic area that promised the potential earnings required under the Plan. Given the nature of Plaintiff’s injury and his capability, as defined by his own treating physician, of performing light to sedentary work, this likely fulfilled Hartford’s obligation under the Plan. However, Hartford went beyond this, conducted two separate vocational market studies and engaged Plaintiff in, and fully funded, an apprenticeship training program, so that Plaintiff would unquestionably be adequately trained and qualified in the occupation of his choice. Plaintiff’s ability to actually secure a job was beyond Hartford’s responsibilities and likely beyond Hartford’s control. At some point, it became incumbent on Plaintiff to take responsibility for actually finding himself a job. Hartford, after all, guaranteed disability benefits, not unemployment benefits.
Cochran v. Hartford Life and Acc. Ins. Co., 2010 WL 259047 (E.D.Mich. Jan. 20, 2010).