Hartford’s “Any Occupation” Review: Why Job Demands and Appeal Records Matter

When a long-term disability policy shifts from “your occupation” to “any occupation,” a list of possible jobs does not answer every question. The policy’s wording, the claimant’s sustained physical capacity, and the assumptions behind each proposed occupation still matter. A recent decision involving Hartford illustrates why those details deserve close attention.

A nurse’s claim after serious lung disease

Krystal Farley, a nurse who experienced serious lung disease following hospitalization and partial lung removal, challenged Hartford’s termination of her ERISA long-term disability benefits. The policy defined “any occupation” by reference to her education, training, or experience and an earnings threshold. The dispute therefore required more than identifying work generally described as sedentary.

Appeal records can shape judicial review

Farley’s appeal was faxed to the correct number on August 30, 2023. Hartford did not decide it within the applicable 45-day period. It later acknowledged receipt but attributed the delay to processing errors.

Applying the disability-claims regulation’s strict-adherence requirement, the district court found that the narrow exception for a de minimis violation did not apply. It reviewed the claim de novo, without deference to Hartford. The court treated the record as closed on October 14, 2023, excluding Hartford’s December 6 decision and accompanying analysis.

That result does not establish that every missed deadline produces the same outcome. The court noted that the Eighth Circuit had not interpreted the newer regulations. For claimants, the practical lesson is to preserve transmission confirmations, delivery evidence, and the insurer’s acknowledgments so the appeal timeline can be established.

Proposed jobs must fit the policy and the evidence

Hartford’s vocational report identified four occupations involving minimum training. But it did not explain the extent of that training or address Farley’s skill deficits. This particular policy did not require retraining. The decision highlights the importance of examining what a proposed job would actually require before accepting it as work a claimant is qualified to perform under the policy.

The court also found that Hartford’s sedentary-work analysis did not reconcile the stated standing and walking demands with its own reviewing doctor’s restrictions. Even accepting Hartford’s favorable interpretation, the court used a combined two-hour standing and walking limit. The issue was the fit between the restrictions and the occupational analysis; the decision should not be read as assigning identical standing and walking demands to every sedentary job.

What the ruling means for claimants

The court granted Farley summary judgment, vacated the denial, and remanded for renewed full and fair review. It did not order an immediate benefits award. Claimants facing an “any occupation” termination can usefully focus their appeal evidence on the exact policy language, sustained functional limits, and any unsupported training assumptions.

For information about disability claims, visit Feden Law Group or schedule an initial consultation.

Case: Farley v. Hartford Life & Accident Ins. Co., 2026 U.S. Dist. LEXIS 227062 (E.D. Mo. Sept. 30, 2026). The court’s public docket notice identifies the order and judgment.

This article provides general information, not legal advice. Reading it does not create an attorney-client relationship.