ERISA-First Circuit Upholds Termination Of Disability Benefits Due To A 24 Month Limitation In The Plan For Disabilities Relating To Mental Health Conditions

In Dutkewych v. Standard Insurance Company, No. 14-1450 (1st Cir. 2015), the First Circuit Court of Appeals (the “Court”) faced the following matter. Plaintiff Mark Dutkewych is a participant in a disability plan (the “Plan”), insured and administered by Defendant Standard Insurance Company under ERISA. The Plan limits long-term disability (“LTD”) benefits to 24 months for “a Disability caused or contributed to by . . .: (1) Mental Disorders; (2) Substance Abuse; or (3) Other Limited Conditions.” Applying this Limited Conditions Provision, Standard terminated Dutkewych’s benefits after 24 months, on June 1, 2011. After Dutkewych’s administrative appeal failed, he brought this lawsuit against Standard for unpaid benefits. The district court entered summary judgment against Dutkewych’s claims, and Dutkewych appealed.

In reviewing the case, the Court said that Dutkewych contests Standard’s decision to limit his LTD benefits to 24 months, saying he has been diagnosed with chronic Lyme disease, “a physical illness that is not limited under the terms of the Plan.” Despite the hot dispute between the parties on this issue, this case does not turn on the insurer’s doubts about the validity of Dutkewych’s diagnosis with chronic Lyme disease. Instead, this case turns on the insurer’s application of a different provision of the Plan, the subset of the Limited Conditions Provision related to mental disorders (“Mental Disorder Limitation”).Standard maintains that, even if Dutkewych was disabled as a result of chronic Lyme disease in June 2011, the Mental Disorder Limitation nonetheless applies because his mental disorders, regardless of their cause, contributed to his disability as of June 2011. The Court ruled that Standard’s interpretation of the Mental Disorder Limitation is reasonable and its application to Dutkewych’s case is supported by substantial evidence. Accordingly, the Court affirmed the entry of summary judgment to Standard.

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