Pre-Existing Condition Exclusion Bars LTD Claim Based on Prior Treatment for Low Back Pain

In Hudson v. Principal Life Insurance Co., No. 24-1308 (JRT/ECW), 2026 WL 496683 (D. Minn. Feb. 23, 2026), the District of Minnesota held that a long-term disability claim was barred by a pre-existing condition exclusion where the claimant received treatment for “low back pain” during the policy’s three-month lookback period—even though she later emphasized coccydynia (tailbone pain) as the source of her disability.

Background

The plaintiff worked briefly for her employer before stopping work in October 2022 due to alleged disabling spinal conditions. She later applied for long-term disability (LTD) benefits under an ERISA-governed group policy issued by Principal Life.

The LTD policy contained this pre-existing condition exclusion:

A Preexisting Condition is any sickness or injury, including all related conditions and complications, or pregnancy, for which a Member:

1. received medical treatment, consultation, care, or services; or
2. was prescribed or took prescription medications;

in the three month period before he or she became insured under the Group Policy.

After reviewing payroll and attendance records, the court determined that the policy’s effective date was August 9, 2022, because the plaintiff was not “Actively at Work” on the date coverage otherwise would have begun. That made the applicable lookback period May 9, 2022 through August 8, 2022.

Treatment During the Lookback Period

During the lookback window, the plaintiff:

• Attended a May 18, 2022 telehealth visit for chronic right-sided low back pain with sciatica, received referrals for pain treatment and physical therapy, and was prescribed oxycodone.
• Underwent a July 11, 2022 MRI for lumbar radiculopathy and low back pain, which showed multilevel degenerative changes and canal narrowing.

Months later, her treating physician stated she was unable to work due to low back pain, along with coccydynia and other spinal diagnoses.

De Novo Review Under Oregon Anti-Discretionary Rule

Although the policy contained a discretionary clause, the court applied de novo review. The policy was governed by Oregon law, and Oregon prohibits discretionary clauses in insurance contracts. The court held that the Oregon regulation was not preempted by ERISA because it regulates insurance and therefore invalidated the plan’s grant of discretion.

Court’s Analysis

The plaintiff argued that the lookback-period records referred only to lumbar spine issues—not specifically to coccyx or sacral pain—and therefore did not involve the same disabling condition.

The court rejected that distinction. It emphasized that the claim was denied because the disabling condition was based, at least in part, on low back pain—and she indisputably received treatment for low back pain during the lookback period.

Because her physician identified low back pain as a basis for disability, and she was treated for that same condition during the lookback window, the pre-existing condition exclusion applied. Having found the exclusion dispositive, the court did not reach the separate question of whether she met the policy’s definition of disability.

Life Coverage During Disability Claim

The plaintiff also sought Life Coverage During Disability (LCDD) benefits. The policy required that the insured become totally disabled before age 60. Because the plaintiff turned 60 before the alleged disability date, the court granted summary judgment to the insurer on that claim as well.

Holding

The court denied the plaintiff’s motion for summary judgment and granted the insurer’s motion, holding that:

1. De novo review applied due to Oregon’s anti-discretionary regulation.
2. The LTD claim was barred by the pre-existing condition exclusion.
3. The LCDD claim failed because the plaintiff became disabled after age 60.

Hudson underscores how broadly courts may interpret pre-existing condition exclusions where earlier treatment involves generally described symptoms—such as “low back pain”—even if the claimant later attempts to narrow the disabling diagnosis to a more specific anatomical source.