Helfman v. Ge Group Life Assurance Co‪.‬

After suffering various cardiac episodes in late 2003, Helfman began receiving disability benefits from defendant-appellees Genworth Life and Health Insurance Company, formerly known as GE Group Life Assurance Company ("Genworth"), and Sun Life Assurance Company of Canada ("Sun Life"). Genworth and Sun Life terminated payment of LTD benefits to Helfman in March 2005 and May 2005, respectively. The district court below found that the Employee Retirement Income Security Act ("ERISA") governed plaintiffs plan, as plaintiff had not satisfied the first of four required criteria for the so-called "safe harbor" exemption from ERISA to apply. Applying applicable ERISA standards, the district court upheld defendants termination of plaintiffs disability benefits as not arbitrary or capricious. Helfman appeals the finding that his LTD benefits plans are governed by ERISA and the finding that Sun Lifes termination of benefits was not arbitrary or capricious.