Legal Summary: Santorelli v. Hartford Life and Accident Insurance Company
Santorelli v. Hartford Life and Accident Insurance Company
624 F. Supp. 3d 143 (D. Conn. 2022)
Our client was a program manager at Amtrust, an insurer, before she fell severely ill. She was diagnosed with a severe vascular disorder. She took medical leave from work and her position was cut later that year, leading her to seek disability benefits from Hartford Life Insurance.
She applied for and received short-term benefits from Hartford, but they expired later that year. She then applied for long-term benefits. Hartford denied her long term coverage, claiming that her illness would not prevent her from working an office job. Our client appealed, but Hartford affirmed its decision, after which we brought suit.
The court reviewed the case under the de novo standard, under which one must prove by a preponderance of evidence that they deserve benefits under the relevant policy. See In re DeRogatis, 904 F.3d 174, 187 (2d Cir. 2018); Booth v. Hartford Life & Acc. Ins. Co. of Am., 2009 WL 652198, at *7 (D. Conn. 2009).
Per our client’s policy, she deserved benefits only if, during the first 30 months after developing her illness, she was “prevented from performing one or more of the Essential Duties of … Your Occupation.” Under the policy, “Your Occupation” means one’s occupation “as it was recognized in the general workplace”—not “the specific job [one performs] for a specific employer.” An “Essential Duty” of an occupation “1) is substantial, not incidental; 2) is fundamental or inherent to the occupation; and 3) cannot be reasonably omitted or changed.”
Hartford claimed that the only relevant essential duty of our client’s occupation was working at a desk. However, she argued that she was no longer able to work a desk job after developing her illness, and that she had other core duties such as traveling and working in an office which she could not perform because she was immunocompromised.
After she fell ill, our client needed to go on “strong immunosuppressants to keep [her] disease at bay.” Her treating physician, Dr. Khoa Ngo, “highly recommend[ed] that [she] limit her contact with others” and Dr. Ruben Peredo, the attending physician at the hospital, agreed that our client should “work at home” because she was “too immunosuppressed to be around too many people.” These statements all indicated that our client should not be working at a desk in an office.
Our client also submitted evidence that her illness had damaged her immune system and left her unable to work around other people in an office, but Hartford Life did not address this issue when denying her appeal.
Hartford disagreed with the above physicians’ recommendations but failed to cite any conflicting medical evidence in their conclusion. Hartford relied heavily on a report from Dr. Benjamin Kretzmann, a consultant it hired to review her chart, who opined that our client could work at a desk for six hours a day.
Hartford attempted to counter our client’s physicians’ belief that she could not work in an office by offering examples of her performing other tasks outside the home, such as grocery shopping and visiting a physical therapist. However, the court deemed these examples “too speculative to credit” and found “the recommendations of her doctors to be much more persuasive.”
The court determined that, in denying long-term disability benefits, Hartford did not address whether an essential duty of our client’s occupation was for her to work from her office rather than from her home. The court concluded that it was medically necessary for our client to work from home and remanded the matter to Hartford Life for a “speedy full and fair reconsideration” of whether working in an office is an “essential duty” of her occupation.
