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Donald Kurth, M.D., sought disability benefits after medical conditions impaired his ability to safely and consistently practice medicine. Treating providers documented limitations affecting endurance, cognitive functioning, and the ability to perform complex professional tasks required of a physician.

Hartford denied the claim based exclusively on file reviews conducted by non-examining physicians and declined to obtain an independent medical examination. The insurer discounted treating-provider opinions and framed the evidence as insufficient to establish disability.

After trial, the court scrutinized Hartford’s claims-handling process and its failure to meaningfully engage with the treating medical evidence. The decision highlighted the risks insurers face when denying professional disability claims without examining the claimant or grappling with treating-provider assessments.