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Archer v. Hartford Life & Accident Ins. Co.

Insurer Granted Judgment; Benefits' Termination Reasonable, Based on Substantial Evidence

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DECISION & ORDER Joan Archer (“Plaintiff”) brings this action against Hartford Life and Accident Insurance Company (“Defendant” or “Hartford”) pursuant to the Employee Retirement Income Security Act of 1974 (“ERISA”), §502 (29 U.S.C. §1132) seeking judicial review of the termination of her long-term disability benefits. Before the Court are the parties’ cross-motions for summary judgement. For the reasons set forth below, Plaintiff’s motion is DENIED and Defendant’s motion is GRANTED. BACKGROUND I. Facts¹ From October 2007 to May 2010, Plaintiff worked as an Assistant Store Manager at TJX Marshall’s Department store. Def. St. 4. Through her employment, Plaintiff participated in an employee welfare benefit plan (the “Plan”) which included long term disability benefits (“LTD”) funded by a Group LTD Insurance Policy (the “LTD Policy”), issued and administered by Hartford. Id.

8-10. The Plan also included life insurance benefits provided through a Group Life Insurance Policy (the “Life Policy”), also issued and administered by Hartford. Id. 12. As claims administrator for both the Plan’s LTD Policy and Life Policy, Hartford had “full discretion and authority to determine eligibility for benefits and to construe and interpret all terms and provisions of [t]he Policy” for both plans. Id.

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