Court Affirms Procter & Gamble’s Termination of Long Term Disability Benefits

Plaintiff Christina Saunders was employed by Proctor & Gamble when she had surgery for an ectopic pregnancy. At that time, disability claims for those employed by Proctor & Gamble in Michigan, like the plaintiff, were handled by a third party administrator, the Reed Group (Reed). Even though plaintiff did not return to work on the date her doctor said she could, Reed approved her for total disability benefits.

For an entire year, plaintiff received benefits and continued her quest for a diagnosis and treatment of her unexplained pain. She was diagnosed at various times with several different ailments, but her treating physicians and physical therapist did not place any work restrictions on her.

After a year, Proctor and Gamble contracted with a new third-party administrator, GENEX Services, Inc. In reviewing plaintiff’s file, GENEX found no evidence supporting her claim that she was totally disabled and entitled to receive long term disability benefits, which prompted GENEX to terminate plaintiff’s benefits. As the Circuit Court noted, “Without a doctor’s note stating that Saunders could not work, the GENEX case manager recommended terminating Saunders disability benefits.” Saunders exhausted her administrative remedies in an attempt to have benefits reinstated. When she was unsuccessful, she filed an ERISA lawsuit arguing that she was entitled to total disability benefits. The District Court ruled in favor of Proctor & Gamble and the plaintiff appealed.

Plaintiff Failed to Show How Her Condition Disabled Her

Despite medical records acknowledging that the plaintiff complained of “unexplained, severe, and constant pain,” her treating medical professionals provided no information as to how her pain prevented her from working. In fact, the records noted that she cared for her 2-year-old son without assistance, drove a car and was able to perform other activities of daily living. Only one physician stated that she was “unable to focus enough to work.” That lone opinion did not trump other medical opinions. For example, one treating physician specifically wrote, “I do not have any work restrictions for her.”

No evidence was presented as to the length of time she could sit or stand or amount of weight she could lift or any other evidence of any physical restrictions. Accordingly, the court affirmed the termination of benefits finding, “Overall, the record does not support a finding that Saunder’s pain conditions renders her totally disabled.”

Unchanged Condition Does Not Require Proctor & Gamble to Continue Benefits

The plaintiff also argued that Proctor & Gamble could not terminate her benefits since her condition had not changed in the year that she had been receiving them. The Circuit Court found this not to be a logical argument. The court held that, “As Saunders stated, ironically, in her opening brief, ‘The best that can be said of [GENEX’s] review of Saunder’s claim is that Saunders was never disabled in the first place.’”

This case was not handled by our office, but we believe it can provide help to clients with pain they believe is debilitating and need to provide objective evidence as to how their pain interferes with their ability to perform their job. If you need assistance with a similar issue, or any issue related to your disability claim, contact one of our disability lawyers for a free consultation.

Using the Courts to Move Insurance Coverage Goals Part I


Written by Tim Rozelle, Esq.

In July, August, October and December 2015, Kantor & Kantor filed class action lawsuits against Anthem Blue Cross Life and Health Insurance Company (and 26 other Anthem, Inc.-affiliated health plans nationwide), UnitedHealthcare Insurance Company (and 31 other United-affiliated health plans nationwide) and HealthNet respectively regarding the insurers’ categorical denials of Harvoni drug treatment for Hepatitis C. In denying treatment, the insurers told their insureds that their liver must reach a certain level of scarring (F3 or F4 on an F0-F4 scale) before treatment becomes necessary and would be approved.  In these respective lawsuits, our clients allege that the named insurers violated the Employee Retirement Income Security Act (ERISA) (or allege that the insureds breached insurance contracts) by using internal coverage guidelines (ICGs) to overrule providers’ determinations of appropriate medical treatment. Our clients claimed that the insurers forced them to live with a serious health problem and related issues until their livers became sufficiently deteriorated to approve treatment.

Hurricane Hermine Update – Roof Claims

Tens of thousands of Florida home and business owners have insurance claims for damage caused by Hurricane Hermine.  It is critical that policy holders know their rights.

Hurricane Hermine

I have litigated thousands of insurance claims on behalf of Florida home and business owners.  Many of those claims have involved claims for roof damage.

Almost 100% of home and business owners’ insurance policies issued in Florida are known as “replacement cost” policies.  A replacement cost policy means just what it sounds like: the insurance company is required to REPLACE the damaged property with new.  A simple example will help.

Suppose you have a 25 year old shingle roof and Hurricane Hermine causes damage (I’ll discuss what “damage” is in a moment).  The insurance company is required to pay to replace the old roof with a new roof.  I mean what you just read.  The insurance company must pay for a new roof with no deductions because of the age of the roof.

Now, some FAQ’s:

  • What if the insurance company says my roof needed to be replaced because it was old?  If your roof was functional (even if it had some leaks) the insurance company has to pay for a new roof regardless of the age.
  • What if I patched some leaks in my roof before the storm?  The insurance company agreed to insure your roof in exchange for you paying your premium.  The insurance company has to pay for a new roof.
  • What if my insurance company has an engineer inspect my roof and the engineer says there is no wind damage?  You should let me have your roof inspected for free.  Insurers almost always send out their own engineers or “roof consultants” and they are often paid significant amounts of money by the insurance companies.  Every insurance roof denial I’ve ever won started with the insurance company saying “no.”

Now, what constitutes “damage” under your insurance policy.

First, you do not have to lose a single shingle to be entitled to a full roof replacement.  There are many types of roof damage that entitle you to a new roof.  Certainly, shingles blown into your neighbor’s yard is one of the types of damage that is covered.  But, there are others.

Your shingles have a sealant strip on their underside that is a critical component of their functionality.  Wind can lift the shingles and cause the sealant strip to fail.  The shingle then sits back down where it was before.  However, once the sealant strip is broken the shingles are “damaged” and must be replaced.

Another type of damage is known as “degranulation.”  Every shingle has tens of thousands of granules that serve several purposes.  If some of those granules are blown or knocked off by a storm that is considered “damage.”

Another type of claim occurs when your insurance company agrees to pay for the damage, but they low-ball the price.  I can help with that too.  Insurance companies are required to pay the reasonable costs of replacement.  If your roofer gives you a quote for a new roof, but your insurance company low-balls that quote, let me take a look at your claim for free.

Sometimes may say they don’t think it is fair that the insurance company has to pay for a new roof when the former roof was old, or not in the best of shapes.  You paid for replacement cost coverage, and you are entitled to receive what you paid for.  Your insurance company knew what it was selling to you and determined its premium based on what it sold you.

If your insurance company denies or low-balls your claim, even if you think there is nothing that you can do, let me look at the insurance denial for free.

Finally, if there is only one thing you remember from this blog, let it be this:

“No” is not the end of the inquiry.  It is just the beginning.  Every insurance case I’ve ever won all have one thing in common.  They all started with “No.”

Also, in most of my insurance cases, if I win the insurance company has to pay all of my attorney’s fees and costs.  And, if I lose, I’ll work for free.  Mark Nation

If your insurance claim has been denied, delayed, or underpaid, I’d like to help.  You can call me at 1-800-NationLaw, or email me at

Hurricane Hermine Causes Widespread Damage to Homes and Businesses

Once again, Florida is ground zero for a major hurricane.  On August 1 and 2, 2016, Hurricane Hermine made landfall in Florida.  Hurricane Hermine’s path took the Hurricane directly over Florida’s Big Bend area through Leon County and into Georgia.

There wind and water damage along the direct path of Hurricane Hermine.  However, many parts of Florida outside the direct path of Hurricane Hermine have also sustained severe wind and water damage.  Hermine caused severe wind and water damage all up and down Florida’s entire Gulf Coast – From Naples to Pensacola.  Hermine’s high winds also stretched inland up and down the Florida Peninsula.

I, and my firm, have assisted 1000’s of home and business owners with hurricane insurance claims, including claims for:

  • Roof damage
  • Trees crashing into homes and businesses
  • Structural damage caused by high winds – this is known as “racking” a house.
  • Business Interruption caused by loss of electricity
  • Flood damage to vehicles

Many policy holders assume that their insurance company will “do the right thing” when they submit a hurricane claim.  My experience with 1,000’s of insurance claims indicates otherwise.

If your insurance company denies, delays, or underpays your claim, I can help.

In most of my insurance cases the insurance company must pay my attorneys fees and costs if we win.  And, if I lose, I’ll work for free.

Court Affirms Sun Life’s Disability Benefit Denial

In Schmitz v. Sun Life Assurance Company of Canada (Sun Life), the claimant, Jeff Schmitz, was fired by Banner Engineering in July 2008 on the grounds his work performance was poor. In October 2011, Schmitz was diagnosed with multiple sclerosis. He then filed for disability benefits under the policy which covered him during his employment with Banner. He claimed symptoms caused by his multiple sclerosis were what caused his poor performance resulting in him being terminated. Therefore, he argued, he was disabled at the time he was fired.

Sun Life denied his application and his appeal of the denial on the grounds that he was not disabled when he was employed by Banner or at the time he was fired. Schmitz filed an ERISA law suit in the Minnesota District Court located in Minneapolis. The District Court granted Sun Life’s motion for summary judgment on the grounds that the lawsuit had been filed after the expiration of the statute of limitations. Schmitz appealed to the U.S. Court of Appeals for the Eighth Circuit.

The Circuit Court agreed with Sun Life and the District Court and held that the ERISA lawsuit was barred by the statute of limitations that was clearly laid out in the disability insurance contract. After reviewing the District Court decision, the Circuit Court commented, “Because we conclude that Schmitz’s lawsuit was untimely, we affirm.”

Minnesota Law Concerning Proof of Loss Does Not Apply to this Case

Schmitz argued that his claim was timely under Minnesota statutes which say that claimant’s do not need to provide proof of loss until 90 days after the disability terminates. The Circuit Court held that the statute upon which Schmitz relied “does not apply to group insurance policies like the one at issue here.”

Although ERISA does not establish a statute of limitations for actions concerning disability benefits, when there is a “reasonable limitations period in their contract” it will be honored. After a careful and detailed analysis of the contract, the Court concluded that the last date for plaintiff to file his proof of claim was December 29, 2008, and the last day for filing an ERISA lawsuit was December 29, 2011. His lawsuit was not filed until March 2013, “well after the contractual limitations period had expired.”

The Issue is Limited to Schmitz’s Untimely Filing of his ERISA Lawsuit

Schmitz argued that Minnesota law requires the insurer to prove it suffered prejudice before denying a claim for benefits as untimely. But, the Court said, “That is not the issue presented by this case.” The issue was the timeliness of the filing of the lawsuit and “Minnesota law does not require a showing of prejudice in this context.”

The Circuit Court ultimately concluded, “Because Schmitz did not file his lawsuit until after the limitations period set by the insurance policy had expired, we conclude that his lawsuit was untimely and affirm the judgment of the district court.”

This case was not handled by our office, but it may provide claimants guidance in their pursuit of long term disability benefits when their insurer refuses to take action on their claim. If you need assistance with a similar matter, or any other issue relevant to your disability claim, please contact any of our lawyers for a free consultation.

Alabama Court Upholds Lincoln Life’s Disability Denial to Plaintiff

Susan Till v. Lincoln National Life Insurance Company (Lincoln) is a 74 page opinion in which the plaintiff, a radiology technician who suffered with severe back pain, raised many issues in her pursuit of long-term disability benefits. Till’s application for long term disability benefits was denied and, after she exhausted her administrative appeals, she filed this ERISA law suit.

The Alabama district court for the Middle District of Alabama meticulously analyzed each of the issues and reviewed all of the plaintiff’s medical records. For each individual issue, the court ruled that the plaintiff failed to meet her burden of proof. The court found that, “After careful consideration of the evidence, the parties’ briefs and the relevant law,” the court found in favor of Lincoln Life.

Lincoln Provided Plaintiff a Full and Fair Review and Did Not Unreasonably Disregard the Social Security Determination and Vocational Analysis

The plaintiff was awarded disability under Social Security and argued that Lincoln failed to consider this in denying her disability benefits. But, in Lincoln’s denial letter, it stated that it had “reviewed all documentation in the file.” This included all the evidence that supported her application for Social Security disability benefits and Social Security’s determination along with its vocational analysis. Lincoln also explained in its letter “that the Social Security benefits decision is based on a different plan and interpretation than the ERISA plan.”

After reviewing Lincoln’s denial letter and the entire administrative record, the court held that Till was not denied a full and fair review since, “The administrative record demonstrates that Lincoln reviewed the Social Security determination and the evidence upon which it was based.”

Lincoln Provided a Full and Fair Review and Did Not Disregard the Actual Requirements of Plaintiff’s Job Description

The plaintiff argued that Lincoln erred in that, instead of considering her actual job requirements, it relied on the job description given in the Dictionary of Occupational Titles (DOT). She argued that the DOT information is outdated and should not be relied on. The court noted that, “Plaintiff has not demonstrated that Lincoln disregarded her actual job description during its initial claim review or during the two appeals…Therefore, Plaintiff has not shown that she was denied a full and fair review by Lincoln’s alleged disregard of her actual job description.”

Lincoln’s Decision Denying Benefits Was Reasonable and not Arbitrary and Capricious

In response to plaintiff’s allegation, Lincoln argued that its denial was based on, “the evidence in the record and the opinions of the two independent reviewing physicians.” The court recounted the reports of each treating physician as well as the opinions of reviewing physicians and decided against plaintiff. The court noted that Lincoln’s denial letter explained why it was relying on the opinions of its reviewing professionals and the lack of objective evidence in the file confirming abnormal physical exam findings of her spinal problem and its diagnosis. Finally, “The court concludes that Lincoln had a reasonable basis on which it relied to deny Plaintiff’s benefits, and its decision was not arbitrary and capricious.”

This case was not handled by our office, but it may provide guidance to those who are struggling to provide evidence to their insurers to support their disability claims. If you have questions about this, or any other disability issue, contact one of our disability lawyers for a free case evaluation.

Ohio Court Upholds Unum’s Denial of Accidental Dismemberment Benefits

Collins v. Unum Life Insurance Company of America is a case with an unfortunate result for plaintiff Daniel Collins who fractured his ankle when he fell in the employee parking lot. Initially surgery was performed and various screws put in place to hold the tibia and fibula together and securing the medial malleolus. For about three months, he had no complaints and the fracture appeared to be healing appropriately.

Then, he began having complaints about pain. About six months after the fall, he developed a Charcot ankle, which is misalignment of the ankle joint. His treating physician noted that he suffered from pain due to the fracture “among other issues.” He had more surgery, but continued to have pain. A breakdown of the tibia indicated that he might need a “limb-salvage procedure.”

After numerous problems and more surgeries, approximately one year after the fracture, surgeons amputated Collins leg just below his knew. The pre and post-surgical diagnoses included, among other things, Charcot neuroarthropathy with ankle deformity, ankle fracture and diabetes mellitus. A few months after the amputation, Collins applied for dismemberment benefits under his employee benefit plan and his claim was denied. Unum based its denial on its determination that “Plaintiff’s diabetes partly contributed to the need to amputate Plaintiff’s foot.” Plaintiff’s administrative appeal was denied and he filed this ERISA lawsuit.

Unum’s Accidental Dismemberment Exclusion

The Unum policy which provided plaintiff dismemberment coverage specifically had an exception and did not provide coverage for dismemberment that was “caused by, contributed to by, or resulting from…disease of the body.” The policy also gave discretion and authority to Unum to process and interpret claims under the policy.

The District Court Upholds Unum’s Denial Based on a Sufficient Record Showing the Diabetes Was A Contributing Factor to the Need for Amputation

Plaintiff’s medical history showed that he was responsible for not controlling his diabetes. As a result, he had ankle problems both before and after his fall. A board-certified pathologist, who reviewed plaintiff’s medical records at the request of Unum, determined, with a reasonable degree of medical certainty, that “both the underlying illness and the injury were necessary for the development of the joint pathology that led to the amputation.” In evaluating these facts, the court held that “Unum’s decision to deny Plaintiff’s benefits application was not arbitrary and capricious based on the policy’s bodily disease exclusion.”

This case was not handled by our firm, but we believe it can be instructive to those struggling to obtain benefits under their insurance’s dismemberment coverage. If you have questions about this case, or any matter relevant to your dismemberment or disability coverage, contact one of our experienced attorneys at Dell and Schaefer for a free consultation.

Appeals Court Upholds Hartford’s Termination of Disability Insurance Benefits

In Rassekh Sobh v. Hartford Life and Accident Insurance Company, Hartford paid the plaintiff benefits beyond his own occupation period as a Technical Operations Lead for Chase Bank and into the any occupation period. During that time, plaintiff had two back surgeries and claimed he was disabled. His medical records and reports from his treating physician supported his claim and he received disability benefits for many years from 2009 to 2014. His treating physician, Dr. Dryer, waffled between supporting his disability claim, failing to respond to Hartford’s request for an opinion and reporting plaintiff could work in a sedentary job.

Video Surveillance, Independent Medical Exam, Peer Review and Failure of Dr. Dryer to Respond

Hartford eventually conducted video surveillance of the plaintiff attending his gym over a two-day period of time. On both days, he walked to the gym without any assistance and stayed between 44 and 55 minutes. Hartford sent a copy of the video surveillance to Dr. Dryer for an opinion. When Dryer failed to respond, Hartford commissioned an independent medical exam (IME) by Dr. Dinenberg, a board certified orthopedic surgeon, who also conducted a peer review of plaintiff’s medical records. An Employability Analysis (EA) was also performed.

Dr. Dinenberg determined that plaintiff could work in a sedentary job and the EA discovered several different occupations for which he was suited. As a result of the reports, Hartford terminated plaintiff’s long term disability benefits. Plaintiff filed an administrative appeal.

Administrative Appeal

In response to plaintiff’s administrative appeal, Hartford sent the medical records for another peer review. The physician agreed plaintiff could engage in sedentary work. Meanwhile, Dr. Dinenberg was finally able to contact Dr. Dryer who agreed Sobh could perform sedentary work. Based on these opinions, and the video surveillance, Hartford upheld its decision to terminate benefits and plaintiff filed the ERISA lawsuit in the Florida district court which sided with Hartford and Plaintiff Appealed.

Eleventh Circuit Unpublished Appellate Opinion

The appellate court opinion came down on the side of Hartford and upheld the district court’s decision. The Eleventh Circuit court specifically stated that, “Here, the lack of response from Dr. Dryer, in conjunction with the surveillance video, the opinion of Dr. Dinenberg, and the Employability Analysis sufficiently substantiated Hartford’s decision to terminate Sobh’s benefits.”

The court concluded its analysis by holding, “In light of this evidence, we find no error in the administrator’s decision to terminate benefits. At the latest, Sobh was no longer disabled as of October/November 2014, and Hartford properly discontinued his benefits.”

This case was not handled by our firm, but we believe it can be instructive for those who have been under long term care by a physician who ignores requests by an insurer to respond to requests for disability opinions. If you have questions about this, or any other aspect of your disability claim, contact one of our experienced disability attorneys for a free consultation.

California Judge Allows Lawsuit for Intentional Infliction of Emotional Distress Due to Manner in Which MetLife Investigated Disability Claim

Kresich v. Metropolitan Life Insurance Company (MetLife) is a federal case out of the Northern District of California favorable to a plaintiff who was harassed, accused of lying and oppressed during the processing of his disability claim. Because of MetLife’s conduct, the plaintiff sued for intentional infliction of emotional distress (IIED). Despite MetLife’s vigorous argument that the claim was preempted by ERISA and the plaintiff could not pursue his tort action, the court disagreed and found in favor of the plaintiff. Relying on precedent, the court stated “Plaintiff’s IIED claim stems not from the handling and disposition of his claim, but from independent allegations of harassment and oppressive conduct. There is no alternative enforcement mechanism under ERISA by which Plaintiff could bring such a claim.”


Kreisich was a vice-president for Kaiser Permanent Controller when he had to quit work due to severe and chronic back pain. Pain medications caused him side effects so serious that he was unable to work. He filed a claim for disability with his insurer, MetLife. Even though MetLife eventually determined he was entitled to long term disability benefits, he filed suit in state court alleging that during the claims processing, MetLife:
• Intentionally delayed scheduling independent medical exams (IMEs).
• Intimidated him into attending multiple IMEs knowing the exams would cause him additional pain and emotional distress.
• Ignored his correspondence.
• Demanded time extensions.
• Accused him of lying about his pain and exaggerating it.
• Purposely misstated and misrepresented statements made by the plaintiff and his treating physicians.
• Put pressure on him to drop his claim, return to work and accept a smaller settlement than one to which he was entitled.

Plaintiff alleged that by these acts, MetLife “engaged in extreme and outrageous conduct by unnecessarily prolonging review of his claim and causing severe mental distress.”

MetLife removed the case to federal court and argued that plaintiff’s state claim was preempted by ERISA and he should not be allowed to pursue it. The court carefully analyzed precedent and determined IIED claims that do not depend on whether or not disability benefits have been awarded are not preempted.

Preemption Analysis

The court pointed out that “ERISA provides a uniform regulatory regime over employee benefit plans.” This means that issues concerning whether or not a claimant is entitled to benefits must be brought under ERISA and decided according to ERISA rules and regulations. MetLife argued that based on this requirement, Kresich’s claims could only be decided under ERISA.

The court clarified that plaintiff’s claims did not concern whether or not he was entitled to benefits, which would be preempted by ERISA, but was independent of the processing since his claim for damages “remained regardless whether his claim for benefits was paid.” The court analyzed many similar cases where tort claims were allowed to proceed against the insurer. If not, then plaintiffs “would be subject to such treatment with no available recourse, and a plan administrator could investigate a claim in all manner of tortious ways with impunity.”

Since, in this case, the plaintiff “seeks damages from Defendant’s alleged harassing and oppressive conduct that existed wholly independent of the Plan…[and] his IIED claim does not depend on whether or not he was denied benefits” the plaintiff was allowed to pursue his IIED claim for damages against MetLife.

This case was not handled by our office, but it may provide claimants guidance in their pursuit of tort claims against their insurers when the insurer has engaged in wrongful conduct during the processing of the claim for disability benefits. If you need assistance with a similar matter, please contact any of our lawyers for a free consultation.

States Advance Policies to Help Immigrants Stay Healthy While Feds Are at a Standstill

Young girlCongressional inaction on immigration reform is effectively leaving a huge void, and states have been stepping up to fill that void with public policies that reflect reality. Last week, we saw another example of the consequences of this federal inaction. The United States Supreme Court, reduced to eight Justices due to Congress’s failure to hold hearings on President Obama’s appointment to fill the Scalia vacancy, failed to reach a majority opinion and instead affirmed the Fifth Circuit Court’s ruling in United States v. Texas. This failure left intact a preliminary injunction blocking the Deferred Action for Parents of Americans (DAPA) and the expansion of the 2012 Deferred Action for Childhood Arrivals (DACA+) programs. These programs promised temporary relief from deportation for an estimated four million immigrants—long-term residents who are raising families, running businesses, and contributing to the vibrancy of our communities.

Importantly, the deferred action policy that has been in place for the last four years is not affected by this ruling. President Obama stated that with DACA+ and DAPA he has pushed to the limits of his executive authority.Immigrant organizations and their allies will continue to fight for comprehensive immigration reform.

In the meantime, states and local governments are leading the way to craft policies that affect immigrants that are both compassionate and commonsense. On the healthcare front, a growing number of states and local governments are doing their part to provide immigrants with the health coverage they need in order to grow and thrive. Immigrants work, play, pay taxes, go to school, raise their families, ride the bus, and live their lives alongside non-immigrants everyday. Given that, many states have correctly reasoned that providing public health care coverage for all people improves the immunity and safety of the entire community by reducing communicable diseases. These states have decided that immigrants should have access to immunizations, vaccinations, doctor’s visits, and hospitalizations if they need it, as well as the long-term benefits that health coverage provides.

Five states and the District of Columbia provide public health insurance to undocumented children, and counties and cities throughout our country have created programs that increase access to primary and specialty health care for low-income uninsured individuals, including undocumented adults. Illinois is a leader on this front. Through its All Kids program, Illinois was the first state to provide health insurance to low-income children regardless of immigration status. As a result, Illinois has one of the lowest uninsurance rates for children in this country—and it continues to lead by building a campaign to provide statewide health coverage for the remaining uninsured, including undocumented adults, as well as exploring other ways to increase access to health care. California’s governor and legislature just asked the federal government for permission to allow undocumented adults to purchase unsubsidized private health insurance on their state-based marketplace. California and New York provide health coverage to DACA status individuals. Advocates in New York are proposing innovative coverage options for uninsured immigrants, and New York City launched a pilot of its program to increase uninsured immigrants’ access to health care. Minnesota’s Health Care Financing Task Force recommended expanding eligibility of its public insurance program, Minnesota Care, to include undocumented immigrants.

Millions of immigrants are rooted in this country and deserve to be able to come out of the shadows and fully participate in every aspect of society. States and local governments are pushing the envelope to craft health care policies that reflect this reality. Hopefully, people working in the highest levels of the branches of our federal government will be inspired to do the same.