Illinois Court Denies Parties' Cross-Motions for Summary Judgment In ERISA Disability Case, Finding Significant Factual Disputes

An Illinois District Court denied the parties’ cross-motions for summary judgment in an ERISA disability case, finding significant factual disputes remained. The court likely ordered a trial.

The Disability Claim

Mr. Hutten, a former software developer, submitted a claim for long-term disability benefits with ReliaStar. Mr. Hutten’s occupation was classified as requiring sedentary physical demand. Mr. Hutten stopped working in 2013 due to psychosis and intractable epilepsy. ReliaStar approved his long-term disability benefits due to his alcoholism and depression. ReliaStar informed him that the policy limited him to only 24 months of payments if his claim was not due to a physical disability. Mr. Hutten then informed ReliaStar he also had disabling back pain and provided medical records to support his claim.

Mr. Hutten timely appealed ReliaStar’s termination and claimed multiple disabling medical conditions including epilepsy, dementia, traumatic brain injury, major depressive disorder, migraines, and spinal stenosis. In support of his appeal Mr. Hutten provided medical records from a pain management doctor as well as a neurologist, a neuropsychological evaluation, and a functional capacity evaluation. In response to the appeal, ReliaStar had two physician consultants review the medical records. One of ReliaStar’s physicians called the majority of Mr. Hutten’s medical conditions and his doctors’ opinions while the other opined Mr. Hutten suffered from depressive disorder. ReliaStar upheld its termination of disability benefits.

Motion for Summary Judgment

Most ERISA disability cases are decided on the record, through cross-motions for summary judgment. Summary judgment is proper when there is no genuine issue of material fact in dispute and the moving party is entitled to judgment as a matter of law. When determining if there is a genuine issue of material fact in dispute, the court looks at the evidence in favor of the party opposing the motion. If there is doubt as to whether an issue of fact exists, then summary judgment must fail and trial is typically ordered.

In the Hutten case, the court noted there were significant facts in dispute as to whether or not he had the alleged multiple medical conditions, the cause of those conditions, and whether or not those conditions were disabling. The court found these issues needed to be resolved during a bench trial in its capacity as a finder of fact. The denial of cross-motions for summary judgment in the Hutten case is uncommon, as ERISA disability cases are often decided on the established record. For this reason, it is critical to have an experienced ERISA attorney handling your case.

Working with an Experienced Disability Insurance Lawyer is Important

This law firm has always focused only on disability insurance law. Our ERISA lawyers are very familiar with the complexities of ERISA. We help people like Mr. Hutten every day in their fight for disability benefits. This includes successfully seeking discovery from the insurance company.

This firm has significant experience fighting all major disability insurance companies, including ReliaStar, and has won several major disability lawsuits against insurers. Our wins have created new law that protects disabled workers.

We can help with:

The firm represents clients nationwide with disability claims governed by federal law, even if we are not located in your state.

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