In his ruling, US District Judge James Robart of the US District Court for the Western District of Washington rejected the notion that the plan should be able to infer from the circumstances of the case that Byron Boyd’s crimes were tied to his illness. The ruling was in a lawsuit by Boyd against the United Transportation Union (UTU).
According to the court, there was no evidence that Boyd’s crimes while serving as UTU president caused any particular condition, nor was there evidence indicating he had pre-existing conditions that deteriorated as a result of his criminal acts.
Boyd was indicted in September 2003 for a multi-year criminal conspiracy beginning as early as 1994 and ending in 2003.
The indictment charged Boyd with mail and wire fraud, interstate transportation in aid of racketeering, bribery, embezzlement from a labor organization, and various other crimes, according to the ruling. He eventually pleaded guilty to criminal charges including mail and wire fraud, racketeering, bribery, and embezzlement, the court said.
Beginning in 2000, Boyd began seeing a physician for various stress-related health conditions, including diabetes, and hypertension. After he was indicted, Boyd contacted his physician complaining of an extraordinary amount of stress, prompting the doctor to write a letter to the UTU recommending that the union place Boyd on permanent and total disability so that his health would not further deteriorate, according to the court.
But, based on the UTU’s summary plan description that allowed disability benefits to be denied if the underlying conditions were caused by an injury suffered while “engaging in a willful criminal enterprise,” the plan committee turned down Boyd’s benefits request.
Boyd then filed a lawsuit against the union and plan arguing that his application for benefits had been wrongly turned away.
The court agreed. “Defendants have failed to meet their burden to show causation,” Robart wrote in his latest ruling . “There is no evidence that Mr. Boyd’s criminal acts caused any particular medical condition.”
The case is Boyd v. United Transportation Union Insurance Association, W.D. Wash., No. C05-1413JLR, 10/17/06 .
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