Court Upholds Hartford’s Denial of Accidental Death Benefits After Employee’s Termination

In Estate of Sydney Green v. Hartford Life & Accident Insurance Co., No. 24-CV-1910-ABA, 2025 WL 2986815 (D. Md. Oct. 23, 2025), the United States District Court for the District of Maryland granted summary judgment in favor of Hartford Life & Accident Insurance Company (“Hartford”), finding that it did not abuse its discretion when it denied an accidental death and dismemberment (AD&D) claim brought by the estate of a former Piedmont Airlines employee.

Sidney Green worked for Piedmont Airlines, a subsidiary of American Airlines, and was covered under an employee welfare benefit plan governed by ERISA and administered by Hartford. The plan included both life insurance and AD&D coverage, each providing a $75,000 benefit. Mr. Green died in a motorcycle accident on June 1, 2019. Although Hartford approved and paid the life insurance benefit, it denied the AD&D claim after Piedmont reported that Green’s employment had been terminated on May 22, 2019—about a week before his death.

The distinction between the two coverages proved critical. While the life insurance portion of the policy extended coverage for 31 days after termination, the AD&D policy contained no such extension. Because the plan limited AD&D benefits to “active, full-time employees,” Hartford concluded that Green was not covered at the time of his accident.

Mr. Green’s mother, acting as administrator of his estate, appealed the decision, contending that he had not been terminated and that his employment continued until the day of his death. Hartford, however, determined that the appeal was untimely. Its denial letter, issued on June 21, 2023, provided the estate until September 8, 2023, to submit an appeal. The estate did not send its written appeal until November 16, more than two months late. The court found that under ERISA, exhaustion of plan remedies is a prerequisite to litigation and that Hartford properly treated the appeal as untimely.

Even assuming the appeal had been timely, the court held that Hartford’s decision was reasonable under the abuse-of-discretion standard. The plan conferred full discretionary authority on Hartford to interpret its terms and determine eligibility for benefits. Relying on employer records, Hartford determined that Green’s employment ended on May 22, 2019, and therefore his AD&D coverage had terminated before his death. The court found that reliance on the employer’s records was appropriate and supported by substantial evidence.

The estate argued that Piedmont failed to follow its collective bargaining agreement, which required notice to the union before termination. The court rejected this argument, explaining that even if notice was not given, the absence of union involvement did not affect the validity of Green’s termination for purposes of plan eligibility. The court also noted that Hartford had obtained confirmation from Piedmont’s human resources department that Green was involuntarily terminated for violating TSA policies.

The estate also urged the court to consider evidence outside of the administrative record, specifically excerpts from the collective bargaining agreement between Piedmont Airlines and the employees’ union. The estate argued that under the agreement, Piedmont was required to notify the union before terminating an employee, and that its failure to do so suggested that Mr. Green had not actually been terminated. The court allowed limited discovery to explore this issue but ultimately found that the extra-record evidence did not alter the outcome. Hartford had reasonably relied on Piedmont’s employment records—showing that Green’s employment ended on May 22, 2019—and nothing in the collective bargaining agreement or the estate’s submissions demonstrated that the termination was ineffective or that coverage continued beyond that date. The court also noted that Piedmont later confirmed the termination and the reason for it, further supporting Hartford’s conclusion.

Because the estate failed to exhaust its administrative remedies and Hartford’s denial was supported by substantial evidence, the court upheld Hartford’s decision. The ruling underscores the importance of timely pursuing internal appeals and understanding the distinctions between different types of coverage under employer-sponsored plans. While life insurance benefits may extend briefly after termination, accidental death coverage often ends immediately when employment ceases.