Hartford Denies LTD Claim By Collections Rep With COPD And Cardiac Impairments

The case involves Lisa Leif suing Hartford Life and Accident Insurance Company under ERISA, claiming wrongful denial of long-term disability (LTD) benefits. W.B. Mason Company, Inc. employed Ms. Leif as a Collection Representative. Leif suffers from atherosclerotic heart disease, refractory angina, coronary spasms, and COPD. As she was no longer able to work due to these medical conditions, she submitted an LTD claim.

During the claim review, Hartford obtained an occupational analysis from Andrew Berlin, a vocational rehabilitation clinical case manager, and an independent medical review from Dr. Paul Medrek, an occupational medicine specialist. Dr. Medrek also attempted to confer with Ms. Leif’s treating physicians, but peer-to-peer contact was only successful with one provider. Dr. Medrek concluded there was “insufficient documentation…to support complete impairment.”

Hartford denied Leif’s long-term disability claim. Hartford concluded the medical evidence provided purportedly did not demonstrate that Lisa Leif was unable to perform the essential duties of her occupation due to her disabilities.

Ms. Leif appealed Hartford’s denial, arguing that “Hartford’s decision failed to properly address how the stressful nature of her position would exacerbate her underlying cardiac issues, most notably, her high blood pressure and unstable angina.”

During the internal appeal process, Hartford obtained additional peer reviews from a panel of physicians selected by the Exam Coordinators Network. Hartford also reviewed additional hospital records and a Cardiac Medical Source Statement supplied by the claimant.

Hartford sent these independent medical reviews to Ms. Leif’s counsel, who argued that they “did not contemplate how the stress of working as a debt collector would exacerbate her condition, and thus dodged the main issue presented within her appeal.”

However, Hartford maintained its decision to deny the claim, concluding that “the medical evidence does not support that [Ms. Leif’s ongoing] symptoms are of such severity that she would be precluded from performing her own occupation through and beyond the Elimination Period as required by the Policy.”

The plaintiff then brought this action against Hartford Life and Accident Insurance Company. She argued that Hartford wrongfully denied her long-term disability benefits, contending that her medical condition prevented her from performing her job.

In response, Hartford maintained that the medical evidence submitted by the plaintiff did not conclusively prove her inability to perform the essential duties of her occupation, justifying their decision to deny the claim based on the terms of the policy and the evidence available.

The Court’s decision was based on a deferential review standard, meaning the Court looked for whether Hartford’s decision was made arbitrarily and capriciously, given the evidence they had.

The Court ruled in favor of Hartford, concluding that Hartford’s decision to deny long-term disability benefits to Lisa Leif was reasonable and supported by substantial evidence. The Court determined that the medical information provided did not adequately establish that Ms. Leif could not perform the essential duties of her occupation.

Regarding the plaintiff’s argument that Hartford had “discount[ed] the impact occupational stress and risk of harm had on her cardiac health,” the Court “do[es] not read the denial of benefits to have ignored significant material evidence submitted by [Ms. Leif].”