Justia Insurance Law Opinion Summaries

Kevin Byes applied for disability insurance benefits and supplemental security income on July 30, 2007, claiming disability since November 1, 2005. The Commissioner of Social Security Administration (Commissioner) denied benefits. An administrative law judge (ALJ) upheld the Commissioner's decision, concluding that Byes was not disabled from November 1, 2005 through the date of the decision. The district court agreed with the ALJ's decision. The Eighth Circuit Court of Appeals affirmed, holding that substantial evidence supported the ALJ's finding of no severe mental impairment; and (2) the district court correctly concluded that the ALJ had applied the incorrect grid rule in order to determine Byes was not disabled but that the error was harmless. View "Byes v. Astrue" on Justia Law

Aetna Life Insurance Company, as the plan administrator, determined Sharon Wade was no longer disabled and stopped paying long-term disability benefits from Wade's former employer's welfare benefit plan. Wade sought judicial review of Aetna's decision by filing a civil action under ERISA. The district court granted summary judgment in favor of Aetna, concluding that Aetna did not abuse its discretion in terminating Wade's benefits because substantial evidence supported the decision. The Eighth Circuit Court of Appeals affirmed, holding that the district court (1) applied the appropriate standard of review; (2) gave appropriate weight to the Social Security Administration's grant of long-term disability benefits to Wade; and (3) did not abuse its discretion by determining substantial evidence supported Aetna's termination of benefits. View "Wade v. Aetna Life Ins. Co." on Justia Law

A healthcare worker was sprayed in the eye with fluids from an HIV-positive patient. She received preventive treatment and counseling. Her employer initially paid workers' compensation benefits; it later filed a controversion based on its doctor's opinion that the employee was able to return to work. The employee asked for more benefits, but the Alaska Workers' Compensation Board denied her claim. The employee appealed, but the Alaska Workers' Compensation Appeals Commission affirmed the Board's decision. Because the Supreme Court agreed with the Commission that substantial evidence supported the Board's decision, the Court affirmed the Commission's decision. View "Runstrom v. Alaska Native Medical Center" on Justia Law

Employee-Respondent Aletha Johnson hurt her back while working for Employer-Appellant Rent-A-Center, Inc. The company contended that the appellate panel of the Workers' Compensation Commission erred by awarding Respondent workers' compensation benefits. The appellate panel found Respondent was disabled and did not constructively refuse light duty work. The Supreme Court found that Respondent qualified as disabled under section 42-1-120 of the South Carolina Code, and affirmed the appellate panel's decision to award benefits. View "Johnson v. Rent-A-Center" on Justia Law

In 2008, Craig Ali was a police officer for appellant, the village of Oakwood. That spring, his department assigned him to perform traffic-control duties on a highway-construction project overseen by appellee, Kokosing Construction Company, Inc. Ali was injured while performing those duties. At issue was which entity was Ali's employer for purposes of his workers' compensation claim. A district hearing officer with the Industrial Commission of Ohio found that Kokosing was Ali's employer at the time of injury. A staff hearing officer reversed, finding the correct employer was Oakwood Village. The Supreme Court affirmed, holding (1) the commission, when confronted with two potential employers, may, but is not required to, use any of the State ex rel. Lord v. Daugherty and Fisher v. Mayfield factors it believes will assist analysis; (2) therefore, the commission did not abuse its discretion by not directly discussing the three enumerated Lord/Fisher factors; and (3) the staff hearing officer's decision was supported by evidence in the record. View "State ex rel. Oakwood v. Indus. Comm'n" on Justia Law

Maine Public Employees Retirement System (the System) appealed a superior court judgment reversing a decision of the System’s Board of Trustees that denied Petitioner Ellen Goodrich basic life insurance coverage under the group life insurance plan administered by the System. Upon review of the record, the Supreme Court vacated the Superior Court's judgment in part and remanded the case for entry of a judgment: (1) vacating the decision of the Board; and (2) remanding to the Board with instructions to provide Goodrich with prospective basic life insurance coverage after she paid back premiums accrued to date. View "Goodrich v. Maine Public Employees Retirement System" on Justia Law

In these consolidated appeals, the Commission of Industrial Relations (CIR) determined that Douglas County committed a prohibited labor practice when it increased union members' monthly health insurance premiums without negotiating. The County appealed, contending that the parties' collective bargaining agreement authorized its unilateral action and that its action did not change the status quo. The Supreme Court (1) affirmed (i) the CIR's determination that the County committed a prohibited labor practice in failing to negotiate health insurance premium increases; and (ii) the CIR's decision not to award attorney fees; but (2) reversed and vacated those portions of the CIR's orders requiring the County to reimburse union members for increased insurance premiums deducted from their wages, plus interest. View "Employees United Labor Ass'n v. Douglas County" on Justia Law

Appellant Brandon Bentley, a deputy sheriff with the Spartanburg County Sheriff's Department, alleged that he developed Post Traumatic Stress Disorder (PSTD) and depression after he shot and killed a suspect who attempted to assault him. An Appellate Panel of the Workers' Compensation Commission unanimously found that Appellant failed to meet his burden of proof in establishing a compensable mental injury that arose out of an "unusual or extraordinary condition" of employment for a Spartanburg County deputy sheriff. "Whether the shooting and killing of a suspect by a deputy sheriff while on duty is an extraordinary and unusual employment condition such that mental injuries arising from that incident are compensable under the Workers' Compensation Act" was the issue central to this case. Appellant asked the Supreme Court to reframe the issue, take it out of its particular employment context, and ask "whether killing another human being is "unusual." Upon review, the Court held that Appellant's testimony that he "might be in a situation where he might have to shoot someone," similar testimonies by Sheriff Wright that officers were aware of the possibility that they might be required to shoot and kill, Appellant's training in the use of deadly force, and the department's policy addressing when deadly force should be used constituted substantial evidence supporting the Appellate Panel's conclusion that Appellant's involvement in the shooting was not "extraordinary and unusual," but was a standard and necessary condition of a deputy sheriff's job. View "Bentley v. Spartanburg County" on Justia Law

An injured employee (Employee) sought workers' compensation benefits for a work-related injury. A claims adjuster with Employer's workers' compensation insurer's (Insurer) third party administrator denied the claim. The Division of Workers' compensation determined that Employee was entitled to medical and temporary income benefits. Employee subsequently brought a bad faith action against Insurer, its third party administrator, and the claims adjuster (Defendants). During discovery, Employee sought communications made between Insurer's lawyer and Employer during the administrative proceedings. Defendants argued that the attorney-client privilege protected the communications. The trial court held that the privilege did not apply. The court of appeals subsequently denied mandamus relief. The Supreme Court affirmed, holding that the attorney-client privilege did not protect the communications between Insurer and its insured. View "In re XL Specialty Ins. Co." on Justia Law

Employee suffered an injury during the course of his employment that was compensable under the Texas Workers' Compensation Act. Petitioner insurance company provided workers' compensation coverage to Employee's employer. Petitioner disputed the impairment rating of twenty percent assigned by the doctor in the administrative proceedings. A hearing officer issued a decision finding that Employee had an impairment rating of twenty percent. The Division of Workers' Compensation upheld the decision. Petitioner appealed. The trial court granted Employee's plea to the jurisdiction and dismissed the case. The court of appeals affirmed. At issue on appeal was whether a reviewing court lacks subject matter jurisdiction to resolve an impairment rating appeal if the only rating presented to the agency was invalid. The Supreme Court reversed, holding that the absence of a valid impairment rating does not deprive the court of jurisdiction. Remanded. View "Am. Zurich Ins. Co. v. Samudio" on Justia Law