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 She argued that the DOT information is outdated and should not be relied on.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.