In Zaccone v. Standard Life Insurance Company, the court held that the US Supreme Court decision in Conkright v. Frommert does not nullify the Illinois statute prohibiting the inclusion of discretionary language in health and welfare insurance policies and that state statutes banning discretionary language are not violative of congressional intent. The court held that the Illinois statute is not preempted by ERISA. As a result, the court concluded that the de novo standard of review will apply. Zaccone v. Standard Life Ins. Co., 10 CV 00033, 2013 WL 1849515, 2013 U.S. Dist. LEXIS 62062 (N.D. Ill. May 1, 2013).

When Should You Hire a Long-Term Disability Attorney?
For physicians, executives, consultants, business owners, and other professionals, your ability to work is often tied to years of training, specialized knowledge, and significant financial responsibility. When an illness or…

