Rogala v. Hartford Life & Accident Insurance Co.

CourtDistrict Court, D. Oregon
DecidedOctober 25, 2021
Docket3:20-cv-01556
StatusUnknown

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

Bluebook
Rogala v. Hartford Life & Accident Insurance Co., (D. Or. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

MICHAEL ROGALA, Case No. 3:20-cv-01556-JR

Plaintiff, OPINION & ORDER v.

HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY,

Defendant. ________________________________

RUSSO, Magistrate Judge: The Employee Retirement Income Security Act (“ERISA”) provides that an ERISA plan participant may bring a civil action in federal court “to recover benefits due to him under the terms of his plan, to enforce his rights under the terms of the plan, or to clarify his rights to future benefits under the terms of the plan[.]” 29 U.S.C. § 1132(a)(1)(B). Plaintiff Michael Rogala brings this action to challenge the decision made by defendant Hartford Life and Accident Insurance Company, denying him long-term disability benefits under the plan. As the Policyholder, Oracle America, Inc. (“Oracle”) established the plan which plaintiff argues entitles him to benefits. Mr. Rogala, who worked as the director of global business operations for Oracle, argues that he was disabled under the Plan for symptoms of Severe Major Depressive Disorder starting on May 8, 2017. Defendant counters that Mr. Rogala does not qualify as an active employee during the relevant period, and that the medical evidence does not support his eligibility for long term disability (LTD) benefits. For the reasons described below, the Court finds that Mr. Rogala is not Page 1 – OPINION & ORDER entitled to long term disability benefits under the Plan, and therefore defendant’s motion is granted.1 DISCUSSION Under Fed.R.Civ.P. 52, the Court recites at length its findings of fact and conclusions of law. But this case can be boiled down to two key questions: (1) Was plaintiff an “active” employee

at Oracle before his termination such that he qualified for Plan benefits? And (2), assuming plaintiff did qualify, did he establish that his disability lasted throughout the 90-day elimination period and two-year mental illness limitation? Because the answer to both questions is “no,” the Court finds the plaintiff is not entitled to the benefits at the heart of this case, grants defendant’s motion, and enters judgment for defendant. FINDINGS OF FACT A. The LTD Plan Issued to Oracle America, Inc. 1. Hartford Life issued Group Policy No. GLT-395175 (the “Policy”) to Oracle America, Inc. (“Oracle”), the former employer of plaintiff Michael Rogala (“Plaintiff”). Oracle,

as the Policyholder, established the Group Long Term Disability Plan for Employees of Oracle America, Inc. (the “LTD Plan”). AR 280-318.2 2. The LTD Plan pays benefits to otherwise eligible participants who become “Disabled” while they are insured under the LTD Plan, and who remain Disabled throughout and

1 The parties style their motions differently: one for “summary judgment” on the administrative record, another for “trial” on the administrative record. Despite this difference, the parties both seek relief under Rule 52, and agree that the Court’s standard of review on the plan administrator’s decision is de novo. Following Fed.R.Civ.P. 52(a), the Court issues these findings and conclusions. 2 Plaintiff generally cited the administrative record as “AETROG”, while Hartford cited “HARTROG.” To avoid confusion the Court will refer to the administrative record simply as “AR.” Page 2 – OPINION & ORDER beyond the 90-day Elimination Period. AR 287; see also AR 285 (the Elimination Period is the “first 90 day(s) of any one period of Disability”). Id. 3. A claimant must first prove that he is an eligible participant on the date of his alleged Disability. Under the LTD Plan, “Eligible Class(es)” include “All Active Full-time and Part-time Employees” who meet the other criteria of the LTD Plan. AR 284. An “Active Full-time

or Part-time Employee” is further defined as “an employee who works for the Employer on a regular basis in the usual course of the Employer’s business. The employee must work the number of hours in the Employer’s normal work week.” AR 298. In other words, a claimant is not an “Active” employee if he is not performing actual work on his regularly scheduled workdays. 4. The Plan specifies that a participant’s coverage terminates, meaning that he is no longer insured under the LTD Plan when he no longer is an Active Employee, defined as, among other things, an employee on a “leave of absence.” AR 294. 5. Coverage may still be continued during a “leave of absence” if the absence is (1) authorized, and (2) documented in writing – for example, when an employee is on a pre-approved

vacation or other pre-approved leave of absence. See AR 294-95. 6. To receive coverage under the LTD Plan, once a claimant has proven that he is an eligible participant, the claimant must also prove that he is “Disabled,” defined as “unable to perform with reasonable continuity the Essential Duties necessary to pursue Your occupation in the usual or customary way” during the Elimination Period and for the next 24 month(s). AR 301. 7. The LTD Plan further defines “Your occupation” as: any employment, business, trade or profession and the substantial and material acts of the occupation You were regularly performing for Your employer when the disability began. Your Occupation is not necessarily limited to the specific job You performed for Your employer. Page 3 – OPINION & ORDER AR 298. In other words, a claimant must prove not just that he suffered from some Disability, but also that his Disability prevented him from performing his own occupation as it existed in the general economy. Id. 8. The LTD Plan also requires a claimant to show he is under the “Regular Care of a Physician” to qualify for benefits. AR 287, 293. “Regular Care of a Physician” means “you are

attended by a Physician” whose treatment is “consistent with the diagnosis of the disabling condition” and “administered as often as needed.” AR 301. 9. The LTD Plan also includes a Mental Illness and Substance Abuse Benefits Limitation, which limits LTD benefits due to “Mental Illness” to a maximum of twenty-four months. AR 287, 299. 10. The parties agree that plaintiff’s alleged Disability is a “Mental Illness” and that his claim for LTD benefits is limited to twenty-four months under the LTD Plan. Complaint, ¶¶ 6.1, 6.15. B. Plaintiff Was Not Disabled, Was Not Actively Working, or Under the Regular

Care of a Physician from April 11 to May 7, 2017. 1. Plaintiff was employed by Oracle in California as the Director of Enterprise Operations. AR 1800. 2. On April 10, 2017, plaintiff was arrested and taken to jail. He remained in jail from April 10 to May 7, 2017. AR 982-983, 1117-18. 3. Plaintiff alleges he was Disabled under the LTD Plan beginning May 8, 2017. AR 1799; Complaint, ¶ 6.1. 4. Plaintiff was not an “Active Employee” or “Actively at Work during the period of his incarceration from April 11 to May 7, 2017. On May 18, 2017, Oracle terminated plaintiff’s Page 4 – OPINION & ORDER employment. AR 1800. Plaintiff was terminated for “job abandonment” as he was “unable to be at work” while he was in jail. AR 982-87, 1117-18. 5. The administrative record contains no records of any contemporaneous treatment by any physicians or other health care providers during plaintiff’s period of incarceration. C. Plaintiff Applies for CAVDI Benefits and Tells Hartford Life that He was on

“Vacation” During His Period of Incarceration. 1. On June 1, 2017, plaintiff applied for CAVDI benefits administered by Hartford Life under a separate plan and stated that his alleged disability began on May 8, 2017. AR 1798- 1800. 2.

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Rogala v. Hartford Life & Accident Insurance Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/rogala-v-hartford-life-accident-insurance-co-ord-2021.