>US Magistrate Roger Cosbey of the US District Court for the Northern District of Indiana decided that plaintiff Ronald Rafine’s injuries “resulted from a medical condition” and, therefore, were required to be covered under federal law.
>Cosbey’s ruling said that Rafine worked at Steel Dynamics from 1998 to 2002 and that he was discharged in August 2002 but still covered at the time of his September 2002 suicide attempt. Rafine’s shooting himself in the jaw after a severe domestic argument with his girlfriend left him with a variety of head injuries for which he received extensive hospital treatment. While in the hospital, Rafine was also treated for depression and, although he admitted to doctors that his drinking had increased in the months before the shooting, he said he didn’t feel that he needed alcoholism treatment.
>After Rafine applied for coverage from the Steel Dynamics plan, the plan hired its own medical expert who argued that Rafine didn’t suffer from depression, but that the suicide was caused by his alcohol intake. The plan denied Rafine’s claim, saying it wasn’t liable for “charges incurred in connection with any intentionally self-inflected injury or illness regardless of whether the Coverage Person was sane or insane,” and he appealed. In the appeal, Rafine argued that the suicide was caused by depression and alcoholism. The plan denied the appeal and Rafine filed suit.
>The opinion is here .