Hartford’s ERISA Disability Win Shows Why Functional Evidence Matters
A diagnosis is an important part of a long-term disability claim. But it does not, by itself, answer the question an insurance policy asks: What work can this person perform?
A recent federal decision, Germana v. Hartford, illustrates how that distinction can shape an ERISA disability dispute—and why claimants should pay close attention to both their policy’s definition of disability and the evidence supporting their restrictions.
What the court decided
On September 21, 2026, the U.S. District Court for the District of Massachusetts ruled for Hartford Life and Accident Insurance Company, upholding the termination of long-term disability benefits. Hartford both insured the benefits and administered the claim. Because the policy granted discretion, the court applied arbitrary-and-capricious review rather than deciding work capacity from scratch.
After 24 months, the policy’s standard changed from disability from the claimant’s own occupation to disability from any occupation, as defined by the policy. That definition included qualifications based on education, training or experience and an earnings requirement. Evidence supporting benefits under the first definition would not necessarily establish entitlement under the second.
The court found substantial evidence supporting Hartford’s decision, including medical reviews and the claimant’s own physician’s assessment of sedentary work capacity. It also rejected challenges to Hartford’s notice and claim handling. A psychiatric report submitted almost nine months after the final administrative decision was excluded.
Three takeaways for disability claimants
1. Connect medical evidence to specific work demands.
Treatment records can establish symptoms and diagnoses while leaving important questions unanswered. How long can someone sit? How often must they change position or rest? Can they maintain concentration and a reliable schedule? Where relevant, medical evidence should explain these limitations and their clinical basis. A general statement that someone is disabled may leave the insurer considerable room to interpret the record.
2. Prepare for a change in the policy definition.
An any-occupation review deserves fresh attention. Read the actual definition and its qualifications, then identify what evidence addresses it. If a physician uses a broad phrase such as sedentary work, consider whether the assessment fully explains the person’s restrictions. The goal is an accurate description of capacity, including limitations a short form might not capture.
3. Treat the administrative appeal as a critical opportunity.
This decision’s exclusion of the later report underscores the risk of assuming missing evidence can always be added in court. The court applied First Circuit precedent; rules governing additional evidence vary with circumstances and jurisdiction. Identify gaps early, address the reasons given for denial, and obtain advice about developing the appeal record.
Germana does not mean Hartford always wins or that sedentary capacity defeats every claim. This district-court decision shows why policy language, medical evidence and the standard of judicial review must be considered together.
Feden Law Group welcomes inquiries from people navigating disability-benefit disputes. A consultation can help identify the questions that deserve attention before the next step.
Case: Germana v. Hartford Life & Accident Ins. Co., No. 23-30065-MGM, 2026 U.S. Dist. LEXIS 213527, 2026 WL 2823567 (D. Mass. Sept. 21, 2026). Source: LexisNexis (subscription may be required).
General information only; not legal advice or an attorney-client relationship. Policy terms, deadlines, facts and governing law may affect your claim.