## Facts

- Metropolitan Life Insurance Co. (Metropolitan) issued a group life-insurance policy providing extended disability benefits to employees of General Motors Corporation.
- Chalmers, a General Motors airplane pilot, was an insured under the policy.
- The policy paid disability benefits when an employee became “totally disabled” and unable to work in any job for which the employee was reasonably qualified by education, training, or experience.
- Chalmers suffered a severe heart attack.
- After the heart attack, Chalmers’ pilot’s license was suspended, preventing him from working as a pilot.
- Chalmers filed a claim for extended disability benefits under the policy.
- Metropolitan denied the claim, arguing Chalmers could still perform other aviation-industry work, including positions he had held before becoming a pilot.
- Chalmers sued Metropolitan to recover disability benefits.
- The trial court concluded Chalmers met the policy’s definition of total disability and granted partial summary judgment for Chalmers.
- Metropolitan appealed.

## Issues

1. Whether an insured is “totally disabled” under a group policy requiring inability to work in any job for which the employee is reasonably qualified when the insured can no longer work as a pilot due to loss of a required license but may be physically able to do other aviation-related work.
2. Whether partial summary judgment was proper where the material facts were not genuinely disputed and the disagreement concerned the meaning and application of the policy’s disability language.

## Decision

- The Michigan Court of Appeals affirmed the trial court’s grant of partial summary judgment for Chalmers.
- The court held that, under the policy’s “reasonably qualified” standard, Chalmers was totally disabled because the loss of his pilot’s license prevented him from engaging in the occupation for which his education, training, and work history chiefly qualified him.
- The court rejected Metropolitan’s argument that the ability to perform some other work defeated coverage where the policy language required consideration of what work the insured was reasonably qualified to do in light of his actual vocational background.

## Legal Principles

- “Total disability” in insurance contracts is determined by the policy’s definition and does not require absolute helplessness.
- When a disability clause turns on whether the insured can work in “any” job for which the insured is “reasonably qualified,” the analysis focuses on realistic employability based on the insured’s education, training, and work experience, rather than on a purely theoretical ability to perform some job.
- Ambiguous disability-policy language is construed against the insurer and in favor of coverage consistent with the insured’s reasonable expectations.
- The loss or suspension of a required professional license may constitute total disability when the insured’s primary training and work history are tied to that licensed occupation.
- Summary judgment may be granted when the material facts are not genuinely disputed and the remaining question is the legal effect of contract language applied to those facts.

## Conclusion

Chalmers, a General Motors pilot insured under Metropolitan’s group policy, suffered a heart attack that led to the suspension of his pilot’s license and ended his ability to work as a pilot. Metropolitan denied benefits on the ground that Chalmers could perform other aviation-related jobs, but the trial court ruled that he was totally disabled under the policy’s requirement that he be unable to work in any job for which he was reasonably qualified. The Michigan Court of Appeals affirmed, holding that the policy’s standard required attention to Chalmers’ actual education, training, and work history, which chiefly qualified him to fly, and that the inability to continue in that line of work satisfied the policy’s definition of total disability.


Chalmers v. Metropolitan Life Insurance Co., 86 Mich. App. 25, 272 N.W.2d 188 (1978)