ERISA-Ninth Circuit Interprets A Mental Disorder Limitation On Long-Term Disability Benefits

In Parker v. Vulcan Materials Company Long Term Disability Plan, No. 09-56674 (9th Cir. 2011) (an unpublished memorandum), the long-term disability policy in question (issued by Hartford) had a mental disorder limitation on the payment of benefits. According to the District Court, the policy had a mental or emotional disorder limitation, under which it did not cover any loss caused or resulting from a “[d]isability beyond 24 months after the [e]limination [p]eriod if it is due to mental or emotional disorders of any type.” But what does that mean?

The Ninth Circuit Court said the following on the mental disorder limitation:

“Hartford’s mental disorder limitation is similar to that in Patterson v. Hughes Aircraft Co., 11 F.3d 948, 950 (9th Cir. 1993). The limitation is ambiguous, because it is not clear ‘whether a disability is to be classified as “mental” by looking to the cause of the disability or to its symptoms’ or whether a disability resulting from ‘a combination of physical and mental factors’ is included in the limitation. Id. Since ambiguities are construed against the drafter, [plaintiff] Parker’s illness is not within the limitation if a physical illness contributes to, or is a cause or symptom of, the mental disorder. Id. at 950-51. Thus, if Parker’s depression caused her physical symptoms, she would still be entitled to benefits. Similarly, if her physical problems contributed to the depression and anxiety that Hartford previously found to be totally disabling, she is still entitled to benefits, regardless of the limitation.”

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