Florida Court Upholds Reliance’s Denial of Long-Term Disability Benefits

In Christopher Foglia v. Reliance Standard Life Insurance Company, Plaintiff, a former Vice President of Realogy Group, LLC (Realogy), was awarded long-term disability benefits (LTDs) when he became unable to perform all the duties of his own occupation. He had been diagnosed with numerous medical problems, including HIV, Hepatitis C, and many symptoms that accompany such diagnoses. In addition to his physical symptoms, Plaintiff also had decreased cognitive functioning that made it impossible to perform his job.

After two years, according to the terms of his disability insurance policy, Plaintiff was required to prove he could not perform the job duties of any occupation for which he was otherwise trained and qualified. When the definition changed, the insurance company informed him his claim for LTDs under the new definition was denied. Reliance determined he could work in a sedentary position.

After exhausting his administrative remedies, Plaintiff filed this ERISA lawsuit in the U.S. District Court for the Middle District of Florida. The case was first considered by a Magistrate Judge who made recommendations to the District Court Judge that the decision by Reliance to deny benefits “was reasonable, and it was not arbitrary and capricious.”

Plaintiff filed objections to the Magistrate’s recommendation. After review, the Court agreed with the Magistrate and held that the Reliance did not err in its decision to deny Plaintiff LTDs since he was qualified to work in a sedentary position.

Reliance Correctly Identified Sedentary Occupations That Plaintiff Could Perform

The Plaintiff claimed that Reliance failed to provide its vocational expert with all relevant medical evidence, and therefore, the report of the occupations for which he was qualified was incorrect. The Court disagreed. It listed all the evidence provided to the expert, and it was not error for Reliance to rely on that report.

Reliance weighed all the evidence, and even if it gave more deference to its own expert over the opinions of treating physicians, Reliance had good reasons for its decision, and it was not “wrong in determining that Plaintiff could perform the sedentary occupations listed by Reliance.” Plus, the court noted that treating physicians had submitted reports saying the Plaintiff’s condition had improved from when he was first awarded benefits under the previous definition of disability.

Reliance Gave Proper Weight to the Fully Favorable Social Security Administration’s Decision to Award Disability Benefits to Plaintiff

Reliance acknowledged that Plaintiff received a Fully Favorable award by the Social Security Administration (SSA). But, the Court noted that “receipt of Social Security benefits does not guarantee the issuance of LTD benefits, or vice versa.” Social security cases apply a different standard, “and rely on vocational experts that have no relevance in an ERISA case.” Therefore, Reliance did not err in refusing LTD benefits to Plaintiff even though SS found him disabled.

Court’s Final Conclusion

The Court considered other issues raised by Plaintiff, but ultimately concluded that Reliance had properly reviewed Plaintiff’s claims, the evidence presented by Plaintiff, the opinions of his treating physicians, the opinions of medical peers who reviewed the record, and reports of an independent medical examiners. It ultimately agreed with the Magistrate that Reliance did not err in denying Plaintiff LTDs.

This case was not handled by our law firm, but we believe it can be instructive for those struggling with insurance companies who deny benefits when the insurance company changes the definition of disability. If you have questions about this or any other aspect of your disability claim, contact one of our disability attorneys at Dell & Schaefer for a free consultation.