Kostal v. Life Insurance Co. of North America

834 F. Supp. 2d 882, 2011 WL 2731228, 2011 U.S. Dist. LEXIS 75163
CourtDistrict Court, E.D. Wisconsin
DecidedJuly 12, 2011
DocketCase No. 09-CV-31
StatusPublished

This text of 834 F. Supp. 2d 882 (Kostal v. Life Insurance Co. of North America) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kostal v. Life Insurance Co. of North America, 834 F. Supp. 2d 882, 2011 WL 2731228, 2011 U.S. Dist. LEXIS 75163 (E.D. Wis. 2011).

Opinion

ORDER

J.P. STADTMUELLER, District Judge.

This case concerns an action for alleged breach of contract brought by Diana Kostal (“Kostal”), a State Farm independent insurance agent, against Life Insurance Company of North America (“LINA”), arising from the termination of Kostal’s claim for long-term disability (“LTD”) benefits under a group LTD policy issued by LINA to State Farm Insurance. LINA has moved for partial summary judgment with respect to the amount of recoverable damages only, seeking to limit Kostal’s claimed damages in this action to $1,000. For the reasons stated below, the insurer’s motion for partial summary judgment will be granted.

BACKGROUND1

In June of 2004, Kostal suffered injuries after she was thrown from a horse during a riding excursion in Canada. Kostal was covered by a LTD policy issued by LINA. Kostal applied for and received LTD benefits under the LINA policy at issue for 23 months, commencing at the conclusion of the applicable 180-day benefit waiting period on December 24, 2004, and continuing through November 23, 2006. However, after paying benefits for 23 months, LINA [884]*884reevaluated Kostal’s condition and determined that she was no longer disabled as defined in the LINA policy. Accordingly, LINA terminated Kostal’s benefits as of November 23, 2006. Kostal subsequently filed the present lawsuit alleging that she remains disabled and that LINA breached the LTD policy by terminating her benefits in November of 2006.

The LINA policy at issue contains two definitions of disability, a “regular occupation” definition and an “any occupation” definition. Under the “regular occupation” standard, an insured individual will be considered disabled if “because of injury or sickness ... she is unable to perform all the essential duties of her occupation, or solely due to Injury or Sickness, she is unable to earn more than 80% of her Indexed Covered Earnings from working her regular occupation.” (Lucas Aff., Ex. 1 [Insurance Policy] at 5) (Docket #29-1). For the first 24 months after the 180-day benefit waiting period, the insured is considered disabled and benefits are payable if the insured meets the “regular occupation” definition of disability. (Id). Significantly, during the “regular occupation” period, the LTD benefit is limited to $1,000 per month while the insured’s State Farm agency agreement remains in effect. (Id at 6).

After disability benefits have been payable for 24 months, the insured will be considered disabled only if she meets the “any occupation” definition. Under this standard, an insured is disabled if she is “unable to actively work in any substantially gainful occupation for which she is qualified or may reasonably become qualified by reason of her education, training or experience” or “if she is unable to earn more than 80% of her Indexed Covered Earnings” solely due to the injury or sickness. (Id at 5). During the “any occupation” period, the LTD benefit is limited to $100 per month while the insured’s State Farm agency agreement remains in effect. (Id at 6). If the State Farm agency agreement ends, benefits then increase to $12,000 monthly if the disability began in 2004 and to $14,000 if it started later. (Id).

In this case it is undisputed that Kostal’s State Farm agency agreement remained in effect from the date of her accident to the present time. It is further undisputed that Kostal applied for and received LTD benefits in the amount of $1,000 per month for the 23 month period from December 24, 2004 (when the 180-day benefit waiting period expired) to November 23, 2006. However, after LINA had paid Kostal a total of $23,000 under the “regular occupation” standard, LINA determined that she was no longer disabled from performing her regular occupation and terminated her benefits.

DISCUSSION

“The court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(a); see also Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986); Celotex Corp. v. Catrett, 477 U.S. 317, 324, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986); McNeal v. Macht, 763 F.Supp. 1458, 1460-61 (E.D.Wis.1991). “Material facts” are those under the applicable substantive law that “might affect the outcome of the suit.” See Anderson, 477 U.S. at 248, 106 S.Ct. 2505. A dispute over “material fact” is “genuine” if “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Id.

While LINA’s motion for summary judgment claims to seek only a determination on the amount of recoverable damages, such a determination requires the [885]*885court to answer another significant question. That is, if Kostal is found to have been disabled under the “regular occupation” standard, whether by this court’s determination or by jury trial, is it then appropriate for this court to make a determination of Kostal’s disability eligibility under the “any occupation” standard, when LINA has not been allowed the opportunity to evaluate Kostal’s eligibility for disability under this standard. LINA argues that the principles of ERISA should govern here, and a case such as this must be remanded to the plan administrator for determination of disability under the “any occupation” standard, following a judicial determination that the plaintiff was disabled under the “regular occupation” standard. See Pakovich v. Broadspire Services, Inc., 535 F.3d 601, 605-06 (7th Cir.2008) (finding that when an ERISA plan administrator has not issued a decision on a claim for benefits that is before the court, the matter must be sent back to the plan administrator to address the issue in the first instance). On the other hand, Kostal argues that under this approach, LINA would avoid paying years worth of benefits. However, such an argument is illogical. Admittedly, the ERISA approach of remanding to the plan administrator would delay Kostal’s receipt of benefits if she is indeed entitled to them under the “any occupation” standard; however, she would not be precluded from receiving these benefits entirely.

While this case is not governed by ERISA because Kostal is not an employee of State Farm Insurance, but rather an independent agent, the court still finds Pakovich particularly instructive on whether a court should decide a disability claim not yet decided by the policy administrator. In Pakovich, under similar facts to the present case, the Seventh Circuit explained that the “any occupation” issue had “not ripenfed] into an ‘apple’ ready to be bitten until the district court rendered a disability determination under the [regular] occupation” standard. Id. at 606. Similarly, in this case, it appears premature for the court to address disability eligibility under the second definition when LINA has not had the opportunity to determine whether Kostal was eligible under that standard.

On the other hand, part of the Pakovich

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Bluebook (online)
834 F. Supp. 2d 882, 2011 WL 2731228, 2011 U.S. Dist. LEXIS 75163, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kostal-v-life-insurance-co-of-north-america-wied-2011.