Bernardo Sanchez v. Hartford Life and Accident Insurance Company

CourtDistrict Court, C.D. California
DecidedSeptember 2, 2022
Docket2:20-cv-03732
StatusUnknown

This text of Bernardo Sanchez v. Hartford Life and Accident Insurance Company (Bernardo Sanchez v. Hartford Life and Accident Insurance Company) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bernardo Sanchez v. Hartford Life and Accident Insurance Company, (C.D. Cal. 2022).

Opinion

Case 2:20-cv-03732-JWH-JEM Document 74 Filed 09/02/22 Page 1 of 24 Page ID #:1709

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE CENTRAL DISTRICT OF CALIFORNIA 10 11 BERNARDO SANCHEZ, Case No. 2:20-cv-03732-JWH-JEM

12 Plaintiff, FINDINGS OF FACT AND 13 v. CONCLUSIONS OF LAW PURSUANT TO RULE 52(a) OF 14 HARTFORD LIFE & ACCIDENT THE FEDERAL RULES OF CIVIL INSURANCE CO.; and PROCEDURE 15 DOES 1 through 10, inclusive,

16 Defendants.

17 18 19 20 21 22 23 24 25 26 27 28 Case 2:20-cv-03732-JWH-JEM Document 74 Filed 09/02/22 Page 2 of 24 Page ID #:1710

1 I. INTRODUCTION 2 This case concerns an ERISA claim that Plaintiff Bernardo Sanchez 3 asserts against Defendant Hartford Life & Accident Insurance Co., through 4 which Sanchez seeks short-term and long-term disability benefits. Sanchez was 5 an employee of non-party Illinois Tool Works Inc. (“ITW”). ITW’s disability 6 benefits plans were administered by non-party Aetna Life Insurance Company 7 (“Aetna”). Defendant Hartford acquired Aetna’s group benefits business in 8 late 2017. In connection with that transaction, Aetna appointed Hartford as its 9 attorney-in-fact to administer claims under certain Aetna group plans, including 10 the plan at issue in this litigation. Accordingly, references herein to “Hartford” 11 refer to Hartford acting on behalf of Aetna as its attorney-in-fact. 12 This matter was tried in this Court on July 27, 2021. The issues 13 presented for adjudication were as follows: 14 1. Did Aetna abuse its discretion when it denied Sanchez’s claim for 15 short term disability benefits? 16 2. Is Sanchez is entitled to long term disability benefits? 17 For the reasons set forth below, the Court answers “no” to both questions. 18 II. FINDINGS OF FACT1 19 A. The Self-Funded STD Plan 20 1. ITW operates two separate and distinct employee welfare benefits 21 plans governed by ERISA: a self-funded short-term disability plan (the “STD 22 Plan”) and an insured long-term disability plan (the “LTD Plan”). 23 2. Because the STD Plan is self-funded, ITW pays benefits under the 24 terms, conditions, and limitations of the Plan. In contrast, ITW’s LTD Plan is 25 fully insured through a policy issued by Aetna. 26 1 To the extent that any of the Findings of Fact herein are considered 27 Conclusions of Law, they are adopted as such. Likewise, to the extent that any of the Conclusions of Law in Part III are considered Findings of Fact, they are 28 adopted as such. -2- Case 2:20-cv-03732-JWH-JEM Document 74 Filed 09/02/22 Page 3 of 24 Page ID #:1711

1 3. Aetna is the claim administrator under both the STD Plan and the 2 LTD Plan. 3 4. The STD Plan grants to Aetna discretionary authority to interpret 4 plan terms and to determine eligibility for, and entitlement to, benefits. 5 5. The STD Plan states: “You will be considered disabled while 6 covered under the ITW STD Plan on the first day that you are disabled as a 7 direct result of a significant change in your physical or mental condition caused 8 by a non-occupational illness or injury.” 9 6. The STD Plan provides coverage for only non-occupational illness 10 or injury. 11 7. The STD Plan defines “occupational” illness or injury broadly as 12 that which “[a]rises out of (or in the course of) any activity in connection with 13 employment . . . .” 14 8. A significant difference between the Plans is that while the STD 15 Plan covers only non-occupational illness or injury, the LTD Plan covers both 16 occupational and non-occupational illness or injury. 17 9. The STD Plan provides benefits for a maximum benefit duration of 18 26 weeks after a seven-day waiting period. 19 10. Other income, such as social security benefits, are deducted from 20 the gross monthly benefit. 21 11. To submit a claim under the STD Plan, the participant must give 22 “proof of the nature and extent” of the disability. The Test of Disability is as 23 follows: 24 From the date that you first become disabled, you meet the test of 25 disability on any day that: 26 You cannot perform the material duties of your own 27 occupation solely because of an illness, injury, or disabling 28 pregnancy-related condition. -3- Case 2:20-cv-03732-JWH-JEM Document 74 Filed 09/02/22 Page 4 of 24 Page ID #:1712

1 You are not performing the material duties of your own occupation 2 if you are only performing some of the material duties of your own 3 occupation. 4 12. The LTD Plan has very different features from the STD Plan. 5 Those differences include the following: a 180-day waiting period; coverage for 6 occupational illness or injury; a different definition of disability; a disability test 7 change after 24 months to disability from “any reasonable occupation”; a 24- 8 month benefit limitation for psychiatric condition; and varying offsets and 9 limitations. 10 13. Because the terms of the STD Plan and the LTD Plan are 11 materially different, the fact that a claim is payable or not payable under one plan 12 does not necessarily mean the claim is payable or not payable under the other. 13 B. The Claimant 14 14. Plaintiff Bernardo Sanchez lives in Ventura County, California. He 15 served as a Corporal in the United States Marine Corps during Operation 16 Desert Storm in 1990. He is a decorated Marine, and he was honorably 17 discharged in 1994. After Sanchez completed his enlistment, he earned his B.S. 18 in Public Relations with a minor in Business. 19 15. Sanchez worked essentially the same job for 23 years, but, as a 20 result of multiple corporate buyouts, Sanchez’s employment with ITW began in 21 2011. ITW specializes in the manufacture of automotive service products. 22 Sanchez served as regional sales manager, and he was responsible for selling 23 ITW products and for maintaining existing distributor relationships and 24 securing new ones. Sanchez’s job activities were sedentary, requiring mostly 25 sitting and occasionally standing or walking. His job also required frequent 26 travel. 27 16. While working at ITW, Sanchez believed that he was exposed to a 28 hostile work environment. He received hostile work emails from his supervisor -4- Case 2:20-cv-03732-JWH-JEM Document 74 Filed 09/02/22 Page 5 of 24 Page ID #:1713

1 regarding his job performance, and he concluded that his supervisor was trying 2 to force him to quit. 3 C. The STD Claim for Symptoms of PTSD and Anxiety Arising Out of a 4 Hostile Work Environment 5 17. Sanchez made a claim for disability under the STD Plan for 6 symptoms of post-traumatic stress syndrome and anxiety exacerbated by a 7 hostile work environment. 8 18. On February 1, 2019, through the Department of Veterans Affairs 9 (the “VA”), Sanchez saw Erica Espinoza, N.P., who reported diagnoses of 10 PTSD and anxiety. Nurse Practitioner Espinoza wrote the following in 11 Sanchez’s medical record: 12 [W]orsening PTSD and hostile work environment r/t supervisor 13 interactions x 1 yr that is causing pt to have a “short fuse”. Has 14 worked for company x 21 years. Reports having panic attacks on 15 plane when reading an email from supervisor. Emails are hostile and 16 “personal attacks” with negative feedback. Gets startled and 17 anxious every time he hears a ping on his phone notifying him that 18 he has a new email. States that supervisor is discriminating and 19 singling him out—making him loose [sic.] his confidence. Pt feels 20 weak. He feels that his supervisor is trying to make him quit. Pt 21 states “he can’t do the job anymore” . . . Pt states that he is 22 “terrified of HR” He “doesn’t trust company or HR” . . . . 23 19. Sanchez submitted a claim to Aetna under the STD Plan with a 24 medical note from Nurse Practitioner Espinoza that Sanchez was out of work for 25 six days, from February 1 to 7, 2019. Sanchez made that claim within the STD 26 Plan’s seven-day waiting period. 27 20.

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Bernardo Sanchez v. Hartford Life and Accident Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bernardo-sanchez-v-hartford-life-and-accident-insurance-company-cacd-2022.