The U.S. Court of Appeals for the Seventh Circuit, in Scanlon v. Life Insurance Company of North America, has ruled that a court must fully consider the nature and the duties of a claimant’s job in a Long-Term Disability (“LTD”) benefits dispute.
Facts. An employee filed a claim for benefits under his employer’s LTD plan, claiming he could no longer perform his job functions due to chronic pain and inability to sleep that prevented him from sitting for extended periods of time and affected his cognitive abilities.
To meet the definition of “disabled” under the plan, an employee must be unable to perform the “material duties” of his regular occupation. In evaluating a disability claim, the plan must “consider the duties of the occupation as it is normally performed in the general labor market in the national economy.”
Concentrating on the physical aspects of the employee’s job, two doctors who were hired by the employer concluded that the employee was not entitled to LTD benefits because he did not satisfy the plan’s definition of disability. Accordingly, the employer denied the employee’s claim for LTD benefits. In response, the employee sued in district court and the court dismissed the employee’s claim because it agreed with the employer’s conclusion.
The employee appealed the adverse determination, arguing that the lower court erred because it did not appropriately consider the nature and material duties of his occupation.
Appeals Court. The Seventh Circuit began its review by simply noting that, “after all, [the employee’s] eligibility for benefits turns on what his job is and whether he can do it.” A medical evaluation by the employee’s doctor concluded that due to his medical conditions the employee “could only sit 15 minutes and stand 45 minutes at a time; and in total, he can sit up to 2 hours 50 minutes and stand up to 4 hours 22 minutes in a day.” The Seventh Circuit then stated that the district court failed to appropriately consider this inability to sit for extended periods of time at a computer, as was required by his occupation.
In the lower court’s view, the medical evaluations proved the employee “can perform the active physical tasks that his sedentary job requires” because “he has a medium lift capacity and can kneel, squat, climb stairs, walk, and perform fine-motor tasks.” But the Seventh Circuit determined those tasks are unrelated to his ability to sit at a computer for eight hours a day, one of the main physical requirements of his job. Taking this factor into account, the Seventh Circuit ruled that the employee was unable to work full-time.
With regards to the employee’s pain and sleep disorder, the Seventh Circuit ruled that the lower court had simply failed to analyze how these conditions affected the employee’s ability to perform the cognitive requirements of his job.