The 11th U.S. Circuit Court of Appeals, reversing a decision by the U.S. District Court for the Middle District of Florida, has rejected a disability insurer’s decision denying disability benefits to a woman who suffered a stroke days after giving birth on the ground that her pregnancy amounted to a “pre-existing condition.”
Julissa Bradshaw was a few weeks into a healthy pregnancy and had no other pre-existing medical conditions when she obtained short-term and long-term disability insurance coverage through her employer, through a policy administered by Reliance Standard Life Insurance Company. About six months after her coverage became effective — which was nine days after she gave birth to her daughter — Bradshaw suffered a debilitating stroke.
Bradshaw filed a claim for long-term disability benefits with Reliance. Because she had filed an application for disability benefits within the first 12 months of her employment, Reliance investigated.
It denied her claim, citing Bradshaw’s pregnancy at the time she purchased her policy and asserting that it qualified as a pre-existing condition that had “contributed to” Bradshaw’s stroke.
Bradshaw sued Reliance, alleging violations of the Employee Retirement Income Security Act of 1974, as amended (ERISA).
Reliance moved for summary judgment, and the district court granted its motion, concluding that Reliance’s decision denying benefits was reasonable.
Bradshaw appealed to the 11th Circuit, arguing that Reliance had incorrectly and unreasonably interpreted the policy by applying the pre-existing-condition exception to deny her long-term disability benefits. In Bradshaw’s view, the exception did not apply because she had not received treatment for a stroke during the “look-back period.”
For its part, Reliance claimed that it had reasonably applied the policy’s exclusion for a pre-existing condition because Bradshaw had not been employed for a full year, was pregnant during the “look-back period,” and her pregnancy “played a part in producing” the stroke. More specifically, Reliance justified its denial of Bradshaw’s claim because it viewed her pregnancy as having “contributed to” her stroke.
The Reliance Policy
The Reliance policy provided:
PRE-EXISTING CONDITIONS: Benefits will not be paid for a Total Disability:
(1) caused by;
(2) contributed to by; or
(3) resulting from