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Williams v. Hartford Life and Accident Insurance Co.

April 6, 2010

THERESA WILLIAMS, PLAINTIFF,
v.
HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY, DEFENDANT.



The opinion of the court was delivered by: William M. Skretny Chief Judge United States District Court

DECISION AND ORDER

I. INTRODUCTION

Plaintiff Theresa Williams brings this action pro se under the Employee Retirement Income Security Act of 1974 ("ERISA"), 29 U.S.C. § 1001 et seq., against Defendant Hartford Life and Accident Insurance Company, seeking to recover long-term disability benefits ("LTD benefits") she alleges were wrongfully terminated. This Court has federal question jurisdiction over this action pursuant to 28 U.S.C. § 1331 Presently before this Court is Defendant's Motion for Summary Judgment pursuant to Rule 56 of the Federal Rules of Civil Procedure.*fn1 Plaintiff opposes Defendant's Motion.*fn2 For the reasons discussed below, Defendant's Motion is granted.

II. BACKGROUND

A. Facts

The following material facts are undisputed and taken from the parties' submissions, including the administrative record, exhibits, affidavits, and Defendant's Local Rule 56.1 statements of facts.*fn3

On March 24 1980, Plaintiff began employment with "Entergy Corporation's Arkansas Power & Light Company." (Def's Statement, ¶ 10*fn4 ; AR 528*fn5 .) Through her employment, Plaintiff participated in, and was subject to Entergy Corporation's Long Term Disability Plan ("Plan"). (Def's Statement, ¶ 11.) The Plan was issued and insured by Defendant through a "Group Insurance Policy" ("the Policy"). (Def's Statement, ¶ 1, 11.)

1. The Policy

The Policy provides long-term disability benefits ("LTD benefits") to employees of Entergy Corporation who are "totally disabled." (Def's Statement, ¶ 5.) Under the Policy, an employee is considered "totally disabled" if:

[D]uring the elimination period*fn6 , and for the next 24 months, you are prevented by Disability*fn7 from doing all the material and substantial duties of your own occupation.

After that, and as for as long as you stay Totally Disabled, you are prevented by Disability from doing any occupation or work for which you are or could become qualified by training, education, or experience. (Def's Statement, ¶ 6; AR 180-81.)

Pursuant to the Policy, employees who are totally disabled are paid LTD benefits until they are "no longer disabled," or until they "fail to furnish proof that [they are] continuously Disabled." (Def's Statement, ¶ 8; AR 174.) Additionally, the Policy also contains a provision through which employees may appeal any denial of claims for LTD benefits. (AR 178.)

2. Plaintiff's Medical Issues

In January 1994, Plaintiff developed chest pain. (Def's Statement, ¶ 12.) She was eventually diagnosed with "costochondritis," and less than one year later, on June 27, 1994, she stopped working because of her chest pain. (Def's Statement, ¶¶ 12-13.)

In October 1994, Plaintiff submitted an application to Defendant for LTD benefits. (Def's Statement, ¶ 14.) Although her application was originally denied (Def's Statement, ¶ 19), on February 5, 1999, Defendant approved Plaintiff's application following a number of appeals. (Def's Statement, ¶¶ 20, 25, 36-38.) Thereafter, Plaintiff began receiving LTD benefits. (Def's Statement, ¶¶ 38, 40.)*fn8

3. Defendant's Decision to Terminate Plaintiff's LTD Benefits

By letter dated August 11, 2004, Defendant informed Plaintiff that it was conducting a review of her benefits in order to determine if she continues to meet the Policy's definition of "total disability." (Def's Statement, ¶ 41; AR 200-01.) As a result, Defendant asked Plaintiff to provide it with updated medical information. (Def's Statement, ¶ 41; AR 200-01.)*fn9 Defendant also asked Plaintiff to sign and complete a document entitled the "Authorization to Obtain and Release Information." (AR 200.) Lastly, Defendant informed Plaintiff that if it did not receive the ...


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