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Court Links Plaintiff’s High Blood Pressure to Heart Disease in Denying LTD Benefits Coverage
Insurance Law Update
U.S. Court of Appeals, Seventh Circuit
In Blanco v. Prudential Ins. Co. of Am., 2008 WL 906184, the Seventh Circuit Court of Appeals held that a plaintiff’s high blood pressure constituted a pre-existing medical condition, and barred coverage for long-term disability benefits.
The plaintiff suffered a heart attack about four months after he had started a new job. He applied for both short-term and long-term disability benefits. Prudential Insurance Company of America insured both plans. Prudential paid the plaintiff's short-term disability benefits but, relying on a preexisting condition exclusion, denied coverage for the long-term disability benefits. The plaintiff sued for coverage in Indiana federal court.
The district court found in favor of Prudential, and the plaintiff appealed to the Seventh Circuit Court of Appeals. In analyzing the preexisting condition exclusion, the Seventh Circuit explained that the exclusion applied to two separate scenarios. First, the exclusion applied if the plaintiff received treatment or took medication for the condition for which he was seeking long-term disability benefits within three months prior to the effective date of coverage. Alternatively, the exclusion also applied if the plaintiff had symptoms for which he sought treatment in that same three-month period. Here, the plaintiff had a history of heart disease as well as high blood pressure, and took blood pressure medication during the three months prior to coverage taking effect. Accordingly, the Seventh Circuit held the exclusion applied under the first scenario, as the high blood pressure medication not only treated the plaintiff’s high blood pressure but also his heart condition because the two conditions were linked. Using the same reasoning, the Seventh Circuit also found that the exclusion applied under the second scenario, as the plaintiff had seen his doctor for his high blood pressure within that same three-month period. Thus, the Seventh Circuit affirmed the district court's decision in favor of Prudential.
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