Susan A. Young claimed her LTD benefits were improperly terminated by Hartford after she had suffered an unusual injury to her neck. Young, who was employed as an attorney at Milbank, Tweed, Hadley & McCloy, LLP suffered an injury to her neck in 2004 while she was at home brushing her teeth. Her neck injury required her to undergo several operations, and rendered her unable to work for substantial periods of time. When Young eventually returned to work in 2006 she was restricted to only work part-time.
After several years, Hartford determined Young’s condition had improved to the point that she could return to work full-time. When the company terminated her benefits, Young argued that she was suffering migraine headaches, which made her disabled and unable to return to work full-time. She appealed her termination of benefits, and the Hartford upheld its determination upon appeal. On February 11, 2011, Young moved and Hartford cross-moved for summary judgment. Hartford also moved to strike one of Young’s exhibits.
The court states that Young argued that two of her medical conditions prevented her from earing 80% of her pre-disability income. She also argued that Hartford’s determination that she was no longer disabled was undermined by procedural irregularities such as a conflict of interest and a failure to gather adequate information. The court found Young’s arguments to be unpersuasive and does not find that Hartford abused its discretion in discontinuing Young’s benefits. The court found that evidence from Young’s doctor indicates her neck impairment no longer is preventing her from returning to work full-time at the time Hartford terminated her LTD benefits.
Young also argued that migraine headaches prevented her from returning to work full-time. Although Young’s doctors verified she was suffering from migraines and was being treated with medication, they did not indicate she was incapable of working full-time. The court states the subjective evidence in this matter is weak, as Young did not describe the length of her headaches, or any other evidence to show when these headaches occurred and their duration. According to the court, instances where plaintiffs successfully argued that they should have received LTD benefits because of migraine headaches, the sufferers have provided more extensive information regarding the nature of the migraines and documented with a greater level of specificity why their migraines rendered them unable to work.
Hartford also moved to strike a letter from one of Young’s doctors, which was dated four months after Young’s administrative appeal for LTD benefits was denied. The letter states that Young suffered from “chronic migraines,” but it does not mention frequency, severity or whether they would disable Young from full-time work. The court reviewed the letter and concluded the letter would not affect the outcome of the case.
The court concluded that Young’s motion for summary judgment was denied, and Hartford cross-motion for summary judgment was granted. Hartford’s motion to strike the letter from evidence was also granted.
The case is Alice A. Young v. Hartford Life and Accident Insurance Company, et al.
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