Colby v. Union Security Insurance Co. & Management Co. for Merrimack Anesthesia Associates Long Term Disability Plan

**What Happened** Dr. Colby, an anesthesiologist, applied for long-term disability benefits from his employer's insurance plan. He had previously struggled with substance dependence but was in recovery. Dr. Colby argued he couldn't safely return to work as an anesthesiologist because his job would expose him to controlled substances, creating a significant risk of relapse. The insurance company denied his claim, saying he wasn't currently disabled since he was no longer actively using substances. **What the Court Decided** The First Circuit Court of Appeals ruled in Dr. Colby's favor. The court found that having a significant risk of relapsing into substance dependence can count as a current disability under the insurance plan. The appeals court upheld a lower court's decision ordering the insurance company to pay Dr. Colby's long-term disability benefits. **Why This Matters for Workers** This ruling is important because it recognizes that disability isn't just about current symptoms—it can also include situations where returning to work poses serious health risks. Workers in recovery from addiction may be able to qualify for disability benefits if their specific job duties would jeopardize their sobriety, even if they're currently healthy.