Geiger v. Aetna Life Insurance Co.

Geiger, an account executive, received Aetna group disability insurance coverage. In 2009, Geiger stopped working and obtained short term disability precipitated by lumbar back pain and a 2007 L5S1 discectomy and bilateral ankle pain caused by avascular necrosis of the talar bones. In 2010, Geiger had several ankle surgeries. Aetna determined that Geiger was disabled from her occupation and approved long-term disability benefits, citing “required walking and driving for this occupation.” Geiger received $4,012 per month, 50% of her predisability earnings. Upon her approval for Social Security disability benefits, the amount was reduced to $784. After 24 months, the Plan requires a claimant to be unable to work at any reasonable occupation. In 2012, Aetna’s physician examined Geiger and found her capable of sedentary work. Under surveillance, Geiger was observed driving and visiting stores. The Plan terminated her benefits. In 2013, Aetna reinstated Geiger’s benefits. In 2014, under surveillance, Geiger was seen climbing into and driving an SUV, shopping, and carrying a bag. Aetna again terminated her benefits, citing the surveillance, prior independent peer reviews, a comprehensive clinical review, and occupational information. Geiger filed suit, citing her lack of medical improvement, her worsening medical condition, and the impact of severe pain on her ability to work. The court granted Aetna summary judgment. The Seventh Circuit affirmed, finding that Aetna minimized any conflict of interest stemming from its roles as administrator and insurer; presented sufficient evidence supporting its decision; and properly considered Geiger’s impairment and pain and the surveillance video. View "Geiger v. Aetna Life Insurance Co." on Justia Law