Lora Walker v. Hartford Life and Accident Ins
2016 U.S. App. LEXIS 13988
| 8th Cir. | 2016Background
- Walker, a Minnesota county employee, stopped working full-time in June 2008 after her employer refused a full-time work-from-home accommodation for her Type I diabetes; she filed a long-term disability claim under a Hartford group policy on April 8, 2009, which Hartford denied.
- The Hartford group policy required written proof of loss within 90 days after the start of the period for which payment was owed and barred suit more than three years after that proof was required; applying these terms the district court found Walker’s suit (filed May 2014) time-barred (deadline December 15, 2011).
- Walker sued in Minnesota state court for breach of contract in May 2014; Hartford removed based on diversity and moved for summary judgment; the district court adopted the magistrate judge’s recommendation granting Hartford summary judgment as untimely.
- Walker argued Minnesota’s insurance statute (Minn. Stat. ch. 62A) — particularly § 62A.04’s “standard provisions” — requires proof of loss within 90 days after termination of the liability period (not 90 days after start) and thus the policy limitation should not apply to group policies.
- The Eighth Circuit affirmed: it held § 62A.09(3) unambiguously excludes §§ 62A.01–62A.08 (including § 62A.04) from applying to group policies except where specifically referenced, so the policy’s limitation governed; the court also rejected Walker’s equal-protection challenge.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 62A.04’s standard proof-of-loss and limitation provisions override a group policy’s contract terms | Walker: § 62A.04(2) requires proof within 90 days after termination of the insurer’s liability period and § 62A.04 protections apply to group policies, so policy limitation is invalid | Hartford: § 62A.09(3) expressly excludes §§ 62A.01–62A.08 from applying to group policies unless specifically referenced; policy terms govern | Held for Hartford: § 62A.09(3) unambiguously excludes § 62A.04 from applying to group policies, so policy limitation controls and suit was untimely |
| Proper interpretation of § 62A.09(3) under Minnesota law | Walker: legislative intent and other provisions (e.g., §§ 62A.01, 62A.05, 62A.10) show parity between individual and group protections | Hartford: plain text of § 62A.09(3) explicitly excludes group policies from §§ 62A.01–.08; administrative guidance cannot override clear statute | Held for Hartford: plain statutory text controls; administrative guidance gets no deference because statute is unambiguous |
| Whether administrative guidance (Dept. of Commerce checklists) should be given deference | Walker: agency materials indicate § 62A.04 applies to group policies and merit Skidmore-type deference | Hartford: agency guidance cannot override an explicit statute | Held for Hartford: no deference where statute is explicit; agency guidance cannot conflict with statute |
| Whether § 62A.09(3)’s distinction between group and individual policies violates equal protection | Walker: denying § 62A.04’s protections to group-policy insureds is arbitrary and lacks a rational basis | Hartford: group and individual policies differ (bargaining power, marketing, payment sources), providing legitimate state interests | Held for Hartford: classification bears a rational basis; Walker failed to rebut presumption of constitutionality under federal and Minnesota rational-basis tests |
Key Cases Cited
- Erie R.R. Co. v. Tompkins, 304 U.S. 64 (establishes application of state substantive law in diversity cases)
- Skidmore v. Swift & Co., 323 U.S. 134 (agency interpretations may merit respect but are not controlling)
- Weyrauch v. Cigna Life Ins. Co. of N.Y., 416 F.3d 717 (Eighth Circuit decision involving insurance disputes; not controlling on § 62A.09 issue)
- Romer v. Evans, 517 U.S. 620 (framework for rational-basis review in equal-protection challenges)
- FCC v. Beach Commc’ns, Inc., 508 U.S. 307 (rational-basis review and burden on challenger to negate conceivable bases)
- Allan v. R.D. Offutt Co., 869 N.W.2d 31 (Minn. law: plain statutory language controls; no construction when unambiguous)
- Premier Bank v. Becker Dev., LLC, 785 N.W.2d 753 (Minn. law: courts enforce clear statutory language rather than general purpose)
- In re Guardianship of Durand, 859 N.W.2d 780 (Minn. articulation of state rational-basis test requirements)