ERISA-Sixth Circuit Holds That Claimant Could Be Entitled To Long-Term Disability Benefits, Despite Her Failure To File A Claim For the Benefits By The time Required By The Plan

In Waskiewicz v. UniCare Life and Accident Health Insurance Company, No. 14-1479 (6th Cir. 2015), plaintiff Laura Waskiewicz had worked for Ford Motor Company as a product design engineer from 1990 until October 26, 2010. She subsequently sought long-term disability (“LTD”) benefits under the Ford Motor Company Salaried Disability Plan (the “Plan”). Defendant UniCare Life and Health Insurance Company (“UniCare”) serves as the claims processor for the Plan, which is governed by ERISA. The district court granted summary judgment to UniCare based upon its conclusion that plaintiff did not qualify for benefits under the Plan because she had already been terminated by Ford before she sought those benefits.

The Sixth Circuit Court of Appeals (the “Court”) reversed, ruled that the plaintiff could be entitled to the LTD benefits, and remanded the case back to the district court. The Court said that here, at the onset of her disability (stemming from type-1 diabetes, major depression, and gender identity disorder), plaintiff was a “covered employee” as defined by the Plan and thus to coverage for benefits. While she did not comply with the notification deadlines outlined in the Plan, in that she did not file her claim for LTD benefits prior to termination, that failure is not surprising given that she was suffering from severe mental illness and was unable to comply due to the very disability for which she sought coverage. Provisions in the Plan contemplate the awarding of LTD benefits to employees who become disabled as long as they are working for Ford at the time of onset, which occurred here.

The Court said that, on remand, plaintiff shall be given the opportunity to show that her alleged failure to comply with the notification and other of the requirements for LTD benefits found in the Plan was due to the very disability for which she seeks benefits.

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