vitamin triggers exclusion

What sort of “medical treatment” triggers the pre-existing condition exclusion in an ERISA-governed disability policy?

Can taking over-the-counter vitamin supplements trigger the exclusion?  YES.

Here’s the case of Kutten v. Sun Life Assurance Company of Canada, __ F.3d __, 2014 WL 3562784 (8th Cir. July 21, 2014) (pdf).

FACTS: Kutten had a progressive