SW Legal studies in Business

Drug Addict Who Completes Rehab No Longer Due Disability Coverage
Description

Appeals court held that long-term disability benefits no longer applied to a worker who successfully completed treatment for addiction to narcotics and wanted to remain on disability benefits. Since the worker successfully completed rehab, benefits would not continue.

Topic Insurance
Key Words

Long Term Disability Insurance; Disability; Addiction

C A S E   S U M M A R Y
Facts

Stanford is a nurse anesthetist who administers anesthesia to patients undergoing surgery. He started taking a narcotic painkiller and became addicted to it. He went for treatment for his addiction and then returned to work. He relapsed and so entered treatment again. While in the second treatment program, he received long-term disability benefits provided by his employer’s insurance program. When he returned to work, he began taking the narcotic again and went into treatment for a third time. Again he received long-term disability benefits. When he completed treatment the third time he requested the benefits continue. He was afraid if he returned to work he would begin taking the drug again. The insurer refused and terminated his benefits when he completed rehabilitation treatment. Stanford sued. The district court held for the insurer; Stanford appealed.

Decision

Affirmed. Stanford had successfully completed treatment and was released, judged capable of working. The insurance plan administrator did not abuse its discretion concluding that the risk that Stanford would relapse into addiction if he returned to work did not constitute a disability under the terms of the plan. A disability is an injury or sickness causing physical or mental impairment to such a degree of severity that participants are unable to perform material and substantive duties of their professions. Stanford was judged capable of performing his job, so is due no benefits. Risk of relapse is not covered by the plan.

Citation Stanford v. Continental Casualty Co., 514 F.3d 354 (4th Cir., 2008)

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