Does a limitation on disability benefits under a life insurance policy apply?

"[T]he issue of whether it is the insured or the insurer who bears the burden of proving that a limitation does or does not apply remains unsettled." Seaman v. Mem'l Sloan Kettering Cancer Ctr., 2010 WL 785298, at *10 (S.D.N.Y. 2010). Reliance relies on Hoffmann v. Life Insurance Company of North America, where the court held that a provision limiting the payment of benefits to two years for disabilities based upon a mental disorder was not an exclusion under the policy, and therefore, the plaintiff bore the burden of proving the limitation did not apply. 2014 WL 7525482, at *5-6 (C.D. Cal.

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