In Weyer v. Reliance Standard Life Insurance Company, the U.S. Court of Appeals for the Eighth Circuit has determined that the “but-for” causation standard is appropriate for determining whether mental health limitations contained in a long-term disability (“LTD”) plan are applicable.
Facts. An employee applied for and received LTD benefits under her employer’s plan. The employee suffered from various medical conditions, including chronic fatigue syndrome/myalgic encephalomyelitis, Lyme disease, migraine headaches, neurocognitive disorder, brain fog, clostridium difficile colitis, irritable bowel syndrome, HHV-6, and malnourishment. She also had a history of anxiety and depression.
The LTD policy limited benefits to “an aggregate lifetime maximum duration of twenty-four (24) months” if the individual’s “Total Disability [is] caused by or contributed to by mental or nervous disorders.” The insurer terminated its payment of benefits to the employee after 24 months under this provision and the employee sued in federal court.
The district court found in favor of the employee, noting that the evidence did not suggest that the employee’s depression and anxiety caused or contributed to her inability to work. The insurer appealed saying that even if the employee was totally disabled, her mental health disorders caused or contributed to her total disability so the 24-month clause should be applied.
Appeals Court. The Eighth Circuit said that under the policy’s “caused by or contributed to by” language, the appropriate standard is “but-for” causation, “that is, [the employee’s] anxiety and depression caused or contributed to her total disability.” In other words, but for the employee’s anxiety and depression, she would not have been totally disabled.
The Eighth Circuit next observed that the district court cited several medical opinions in the record as examples that supported its conclusion that the employee’s physical conditions independently rendered her unable to work. Based on this record, the Eighth Circuit found no clear error in the district court’s conclusion that the employee would have been disabled regardless of her mental health condition. It therefore affirmed the lower court’s decision in favor of the employee.