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Bolles v. Principal Life Ins. Co.

Citation: 339 F. Supp. 3d 1195Docket: Civil Action No. 17-cv-01214-PAB-KMT

Court: District Court, D. Colorado; September 12, 2018; Federal District Court

Narrative Opinion Summary

The case involves a dispute over long-term disability benefits between a neurosurgeon and Principal Life Insurance Company. The plaintiff, having become disabled at age 79, was initially granted short-term disability benefits, followed by a limited approval for long-term benefits under the insurance policy, which capped benefits at 12 months for individuals over 72. Contesting this limitation, the plaintiff argued that the policy's 'own occupation' provisions entitled him to two years of benefits. The case was removed to federal court under diversity jurisdiction, where the defendant filed a motion to dismiss under Rule 12(b)(6), asserting that the policy unambiguously limited benefits based on age. The court, applying Colorado law, found no conflict between the 'own occupation' criteria and the age-based benefit limit, determining that the policy was clear in capping the benefits at 12 months for those aged 72 and older. Consequently, the court dismissed the complaint with prejudice, concluding that the plaintiff's claim lacked a plausible basis for relief. The court also acknowledged an error in the plaintiff's short-term disability claim date and affirmed that federal law governs the issuance of declaratory judgments in diversity cases.

Legal Issues Addressed

Benefits Limitation Based on Age

Application: The insurance policy clearly limits long-term disability benefit payments to 12 months for individuals aged 72 and over, despite the 'Own Occupation' provisions.

Reasoning: The policy stipulates a 12-month Benefit Payment Period for individuals aged 72 or older, regardless of the 'Own Occupation' provisions.

Declaratory Judgment in Diversity Jurisdiction

Application: While the plaintiff seeks a declaratory judgment under Colorado law, the federal court's authority to issue such a judgment is governed by federal law in a diversity case.

Reasoning: The court confirms that while the plaintiff seeks a declaratory judgment under Colorado law, the federal court's authority to issue such a judgment is governed by federal law in a diversity case.

Interpretation of Insurance Contracts

Application: Under Colorado law, insurance policy interpretation is a legal matter, emphasizing intent and reasonable expectations of the parties involved, with ambiguous terms construed in favor of the insured.

Reasoning: Under Colorado law, the interpretation of an insurance contract is a legal matter, relying on standard contract interpretation principles that emphasize the intent and reasonable expectations of the parties involved.

Motion to Dismiss under Rule 12(b)(6)

Application: The court requires the complaint to present sufficient factual matter that, if taken as true, renders the plaintiff's claim plausible to survive a motion to dismiss.

Reasoning: The legal standard for survival against such a motion requires the complaint to present sufficient factual matter that, if taken as true, renders the plaintiff's claim plausible.