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United States First Circuit

Dutkewych v. Standard Insurance Company, 14-1450

Defendant insurance company limited plaintiff's long-term disability benefits to 24 months on grounds that plaintiff's stated "chronic Lyme disease" condition satisfied the Limited Conditions Provision of the insurance plan, which limits the plan based on a disability caused or contributed to by mental disorder, substance abuse, or other limited conditions. Applying this provision, defendant terminated plaintiff's benefits completely after 24 months. Plaintiff brought this lawsuit against defendant for unpaid benefits. Summary judgment in favor of defendant is affirmed, where, even if plaintiff was disabled as a result of chronic Lyme disease, the Mental Disorder Limitation nonetheless applies because his mental disorders, regardless of their cause, contributed to his disability.

Appellate Information

  • Decided 03/30/2015
  • Published 03/30/2015


  • Lynch


  • United States First Circuit


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