Former Executive Denied Long Term Disability Benefits After Falling Down Steps of Private Plane

The United States Court of Appeals for the Sixth Circuit recently held that a former hospital executive who sustained injuries deplaning his private aircraft isn't entitled to disability benefits, because his injuries occurred after he left employment. See Sanford v. Life Ins. Co. of N. Am. (6th Cir., No. 14-5332, unpublished 2/13/15). The Sixth Circuit ruled that Life Insurance Co. of North America ("LINA") validly denied the executive's claims for both short- and long-term disability benefits after finding that the executive's allegedly disabling injuries occurred five days after he retired from LifePoint Hospitals Inc. The executive argued that he nevertheless remained in “Active Service” under the terms of the plan, because LifePoint continued to pay him for the four weeks of paid time off he had accrued. Even so, LINA didn't act arbitrarily or capriciously in finding that the executive failed to satisfy the plan's definition of “Active Service,” because it was reasonable for LINA to conclude that the executive was retired rather than on a vacation day at the time of his injury. According to the Court, under this theory, the executive “could not ‘vacation' from his job responsibilities because, having retired, he had no job responsibilities whatsoever.”