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Northbrook Life Insurance Co. v. Clark
Citations: 582 So. 2d 1199; 1991 Fla. App. LEXIS 5557; 1991 WL 101821Docket: No. 90-03499
Court: District Court of Appeal of Florida; June 12, 1991; Florida; State Appellate Court
Appellant Northbrook Life Insurance Company contests a declaratory judgment favoring Appellee Mary Elizabeth Clark, who was a former insured under a group health insurance policy. The trial court ruled that Ms. Clark is entitled to a conversion policy with benefits equivalent to those of her former group contract, a decision affirmed by the court. Ms. Clark, an attorney at Gulfcoast Legal Services, Inc., was covered under Northbrook's group health insurance plan when she was diagnosed with cancer in December 1988. After undergoing surgery in January 1989, she became totally disabled and did not return to work. She received full medical benefits under the group plan until her resignation on June 30, 1989, after which she received an extension of benefits until June 30, 1990. Northbrook informed Gulfcoast of the termination of group coverage effective July 1, 1989. Ms. Clark exercised her right to convert her policy, requesting one with equal benefits, but the conversion policy issued by Allstate did not match the benefits of her original coverage. Northbrook contended that it was only required to provide a conversion policy meeting the minimum standards outlined in section 627.6675, Florida Statutes (1989). However, the court agreed with Ms. Clark that she is entitled to a conversion policy with benefits equal to those provided under the group plan. The court found that section 627.6675 establishes minimum requirements for conversion policies but does not limit the benefits available under the original group policy. The group policy allows for conversion upon the end of employment and stipulates that the terms of the conversion must comply with applicable state laws and regulations. The court concluded that the conversion policy must provide coverage equal to the group policy, with section 627.6675 only serving as a baseline. The court referenced precedent from Blue Cross/Blue Shield of Florida, Inc. v. Shufelt, emphasizing that the legislative intent behind section 627.6675 is to ensure that converted policies reflect the benefits previously available under group coverage. The ruling was affirmed, with the court noting that even under Northbrook's own interpretation, it failed to meet its obligations, as the conversion policy’s benefit factor multiplier rendered it inadequate according to the minimum requirements of the statute.