Artz v. Hartford Life & Acc. Ins. Co. (100 F.4th 921) 7th Cir., May 6, 2024

Words & Phrases

ERISA

Trial Judge

Brett H. Ludwig

Appellate Judge

Scudder

Holding

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.

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