Seventh Circuit Upholds Hartford Life’s Denial of Long-Term Disability Benefits to Systems Engineer with Cardiac Condition

In Slaughter v. Hartford Life & Accident Ins. Co., No. 24-2163, 2025 WL 546909 (7th Cir. Feb. 19, 2025), the Seventh Circuit Court of Appeals affirmed Hartford Life & Accident Insurance Company’s denial of long-term disability benefits to Plaintiff, a systems engineer with a long tenure at Boeing, who sought disability benefits after being hospitalized for heart failure. Hartford denied his claim, citing that Plaintiff did not meet the policy’s definition of “disabled.” The district court upheld this decision, leading to Plaintiff’s appeal. Unfortunately, Plaintiff fared no better in the court of appeals.

The core issue for the court was determining whether Slaughter qualified as “disabled” as defined by the Plan. Slaughter had to establish that he is prevented from performing one or more essential duties of his occupation. Hartford categorized his occupation as “sedentary”, meaning that he sits the majority of the workday with occasional standing/walking for brief periods of time. The court also recognized that a systems engineer must also perform certain cognitive tasks. The district court concluded that Slaughter failed to meet this standard, and in the alternative, found that Slaughter failed to prove he was “under the regular care of a physician” as required by the plan.

A significant part of the court’s decision hinged on the medical evidence provided by Dr. James Ellison, Slaughter’s cardiologist. Dr. Ellison’s treatment notes documented Slaughter’s considerable improvement following his hospital discharge, suggesting he could potentially return to work. Slaughter’s argument heavily relied on testimony from Delores Gonzalez, a vocational expert. Gonzalez claimed that Slaughter’s physical limitations and mental health issues prevented him from working. However, the district court found Gonzalez’s conclusions inconsistent with the medical records, particularly those from Dr. Ellison, which undermined the credibility of her assessment. The court found no legal or factual error with the district court’s findings. In sum, the court found no clear error in the determination that Slaughter failed to prove his cardiac condition left him unable to perform any essential duties as a systems engineer and agreed with the district court that Slaughter was not disabled within the meaning of the Plan. Judgment to Hartford affirmed.