The claimant, Karen Bloom, was a doctor specializing in physical medicine and rehabilitation. She was diagnosed with multiple sclerosis (MS) in 1999 but worked continuously without problems for the next several years before her condition rendered her disabled. Hartford Life denied her claim, she appealed and lost again. She then filed suit under ERISA to collect her benefits. The Sixth Circuit Court of Appeals ruled that Hartford had acted arbitrariliy and caprciously in denying Dr. Bloom's claim. The court was particularly critical of several aspects of Hartford's claims process:
1) Absence of Medical Evidence To Support Conclusions: Hartford determined that Dr. Bloom became disabled in December 2002 but "did not even rely on medical examinations conducted between December 1, 2002, and February 11, 2003 -- the very period in which Hartford determined that Bloom had become disabled."
2) Fabrication of Evidence: Hartford claimed to have relied on a report from a Dr. Marks that Dr. Bloom was disabled as of December 1, 2002. But the court observed: "Nothing in Dr. Marks's report indicates that Dr. Bloom was disabled in December 2002."
3) Ignoring Evidence: Hartford made much of the hours worked by Dr. Bloom. She submitted explanations during her appeal but the court stated, "There is no indication in the record that Hartford considered this information."
These factors led the court to conclude and rule that Hartford Life was arbitrary and capricious in denying Bloom's claim.
