Sloan v. Hartford Life and Accident Ins. Co.

In this 2006 ERISA case, the appellant insurer challenged the U.S. District Court’s determination that the appellee injured party qualified for long-term disability benefits under a plan governed by ERISA. The court first addressed the insurer’s argument that the district court abused its discretion in admitting evidence outside the administrative record. As to the duplicative medical evidence, it held that the district court did not abuse its discretion. As for the nonduplicative new evidence considered, two reasons given by the district court were sufficient to support its decision, i.e., the social security definition of disability was very similar to the definition in the plan, and the district court considered the administrative law judge’s credibility determinations regarding the subjective complaints of pain to be highly probative of the ultimate question of disability. The court turned next to the finding that the injured party qualified for LTD benefits. Under the clear error standard, there was enough evidence to support the findings. Finally, because there was simply no legitimate basis for the insurer’s contention regarding a potential offset of social security benefits at a point in time earlier than January 2001, the district court committed no error when it failed to remand the case to allow the insurer the first opportunity to calculate the offset administratively.

The district court’s decision was affirmed.

If you need assistance navigating your claim for short term or long-term disability benefits under ERISA, or it is time to sue the insurance company, please do not hesitate to give Cody Allison & Associates, PLLC a call (844) LTD-CODY, (615) 234-6000. or send us an e-mail Cody@codyallison.com.  We provide representation nationwide and have successfully sued all the major insurance companies in many states. Our headquarters are located in Nashville, Tennessee.  We offer a free consultation and would love to speak with you.