Ms. Julie Cruz submitted a claim for benefits in May 2021 to Standard Insurance Company under a group long-term disability (LTD) policy sponsored by St. Elizabeth Medical Center. Standard denied Ms. Cruz’s claim and Ms. Cruz commenced legal action against Standard.
The issue before the court was whether Ms. Cruz’s claim would fall under a conventional breach of contract state law or ERISA, a federal statute that creates a cause of action to enforce beneficiary rights under certain employment benefit plans.
However, excluded from the scope of ERISA are “church plans” which fall under the “church-plan exception.” This typically applies to plans maintained by churches or church associations for their employees. 29 U.S.C. § 1003(b)(2).
In 2017, the Supreme Court clarified that the “church plan” exception simply applies to plans established and maintained by (a) a church or association of churches or maintained by (b) an organization with the principal purpose of administering or funding the plan for a church or association of churches. Advoc. Health Care Network v. Stapleton, 137 S.Ct. 1652, 1656 (2017); 29 U.S.C. § 1002(33)(C).
Ms. Cruz’s LTD policy shows that St. Elizabeth “maintains” the plan as a sponsor. Despite St. Elizabeth being associated with the Catholic Church, the Court determined that St. Elizabeth is not a church or an associate of the church.
The Court further concludes that St. Elizabeth’s “principal purpose” is to provide healthcare according to their articles of incorporation. Therefore, the court ruled the church-plan exception under ERISA does not apply to Ms. Cruz’s claim.
Understanding when exceptions to ERISA apply is an important analysis when determining where to file your lawsuit and what type of law applies.
Help from a Lawyer with Expertise in Disability Insurance
Disability insurance law is complex. Hiring an experienced disability attorney is important. Because all disability lawyers at this law firm focus on disability insurance claims, we have expertise in disability insurance law.
That means have:
- Experience with every major disability insurance company;
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The firm can help at any stage of your disability insurance claim, including:
- Submitting a disability insurance claim,
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Because federal law applies to most disability insurance claims, our lawyers are able to represent clients across the country.
Call us at (800) 969-0488 or send us a message online to speak with an experienced disability attorney. Consultations are free.
