Robert Montour v. Hartford Life & Accident Insur

I. Background

As an employee of Conexant Systems, Inc. for approxi- mately thirty-seven years, Montour participated in his employer’s group long-term disability insurance plan, which is a welfare benefit plan governed by ERISA. Hartford is both the insurer and the administrator of the Plan. The Plan grants Hartford, as the administrator, discretionary authority to inter- pret Plan terms and to determine eligibility for benefits,1 and 1 Specifically, the policy provides: Who interprets policy terms and conditions? We [Hartford] have full discretion and authority to determine eli- gibility for benefits and to construe and interpret all terms and provisions of the Group Insurance Policy. MONTOUR v. HARTFORD LIFE & ACCIDENT 15373 it places the burden of proving both initial and ongoing dis- ability on the claimant.

In July 2003 Montour took a medical leave of absence from his position as a telecommunications manager after develop- ing symptoms of acute stress disorder. At the time, he was fifty-five years old. In January 2004, following a period of 180 days during which no benefits were payable under the Plan, Hartford accepted Montour’s application for benefits…