Court: United States District Court for the Northern District of Illinois, Eastern Division
Insurance Carrier: Reliance Standard Life Insurance Company
Claimant’s Employer: Cooper’s Hawk Intermediate Holdings, LLC
Claimant’s Occupation: Senior Human Resources Manager
Disclaimer: Please note that this claim was not handled by the Ortiz Law Firm. It is summarized here for educational purposes.
From Career Momentum to Chronic Health Decline
Jessica Krueger was thriving in her new role as a Senior Human Resources Manager at Cooper’s Hawk when she began to experience debilitating symptoms. Hired in June 2021, she began experiencing severe abdominal pain, diarrhea, migraines, and neurological problems at the end of that year. In March 2022, Krueger applied for long-term disability (LTD) benefits under a Reliance Standard policy, listing postural orthostatic tachycardia syndrome (POTS) as her disabling condition.
Despite strong support from her treating physician, Reliance denied the claim, asserting that POTS was a pre-existing condition based on treatments Krueger received for tachycardia and migraine headaches prior to the effective date of her policy.
Insurer Denies Claim Based on Pre-Existing Condition Clause
Reliance argued that because Krueger had been treated inappropriately for sinus tachycardia and migraine headaches in the three months before her coverage began, her subsequent diagnosis of POTS was excluded under the policy’s pre-existing condition clause. Krueger appealed, submitting extensive documentation, including:
- A formal diagnosis of POTS supported by autonomic testing.
- Statements from several treating providers confirming disabling symptoms.
- Testimony from family members describing her severe functional limitations.
- Medical literature clarifying the distinct nature of POTS and its frequent misdiagnosis.
Despite this, Reliance maintained its denial, claiming that POTS was a pre-existing condition. Alternatively, Reliance stated that even if POTS were not an excluded preexisting condition, it would still have denied her benefits because she failed to prove that she met the Policy’s definition of total disability.
Court Rejects Reliance’s Reasoning
Applying a de novo review, the court sided with Krueger, finding that Reliance failed to meet its burden of proving that the treatment Krueger received prior to coverage was specifically for POTS. The court emphasized:
- Krueger’s pre-coverage symptoms were not definitively linked to her subsequent diagnosis of POTS.
- The insurer could not exclude benefits for POTS simply because tachycardia and migraines are associated with it.
- Objective testing and medical evaluations conducted after the policy became effective confirmed a valid diagnosis of POTS that independently disabled Krueger.
The court also rejected Reliance’s contention that Krueger failed to prove total disability, citing credible evidence that her symptoms severely impaired her ability to work in a demanding human resources position.
Judgment Entered in Favor of the Claimant
The court granted Krueger’s motion, entitling her to LTD benefits under the policy. The ruling reaffirms the importance of accurate diagnostic timelines and cautions insurers against broadly interpreting exclusion clauses without sufficient medical support.
If your disability benefits have been denied due to a misapplied pre-existing condition clause, the Ortiz Law Firm is here to help. We have experience representing clients with complex autonomic disorders like POTS and challenging unfair denials. Contact us today for a free case evaluation.
Here is a PDF copy of the decision: Krueger v. Reliance Standard Life Insurance Company
