Artz v. Hartford Life & Accident Insurance Co.

Federal 7th Circuit Court
Civil Court
Employee Retirement Income Security Act
Citation
Case Number: 
No. 23-2269
Decision Date: 
May 6, 2024
Federal District: 
E.D. Wis.
Holding: 
Affirmed.
Judge: 
SCUDDER

Plaintiff filed a lawsuit under the Employee Retirement Income Security Act after his claim for long-term disability benefits was denied, arguing that the insurance company’s finding that he was not disabled within the meaning of the plan was arbitrary and capricious. The Seventh Circuit affirmed, finding that while the denial letters were not thorough in their explanation of the denial, the plan administrator nevertheless communicated rational reasons for its decision that were based on a fair reading of the plan and the plaintiff’s medical records and this met the requirements under ERISA. (JACKSON-AKIWUMI and PRYOR, concurring)