Four important trends in the ERISA Long-Term Disability Cases from Virginia Federal Courts in 2024
We recently reviewed all of the ERISA long-term disability cases from the federal district courts in Virginia, covering decisions through January 1 to November 7, 2024.
These cases reveal important trends, particularly around insurers’ reliance on procedural standards and objective evidence requirements. Out of the cases reviewed, insurers prevailed in five, while claimants won four, with one mixed ruling. Below, we break down the key patterns observed and offer insights for claimants navigating similar claims.
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1. Objective Medical Evidence is Key
One of the most significant hurdles for claimants was the demand for “objective medical evidence” to support their disabilities. In several cases, courts sided with insurers when claimants lacked sufficient objective documentation, such as diagnostic tests or clinical evaluations.
Case Example: In Learn v. Lincoln National Life Insurance Co., Lincoln argued that the claimant’s subjective reports from family members about her condition did not meet the plan’s criteria for objective medical proof. The court ultimately agreed, ruling in favor of Lincoln and underscoring the weight courts place on objective evidence under ERISA plans.
Takeaway for Claimants: Secure comprehensive medical documentation, including diagnostic tests and specialist evaluations, wherever possible to support your claim.
2. Social Security Offsets as a Common Dispute
Social Security offsets were another frequent issue, particularly where insurers attempted to apply offsets to earned-income Social Security benefits rather than just Social Security Disability Insurance (SSDI) benefits. Courts generally ruled that only SSDI should be offset, but this distinction can be nuanced.
Case Example: In Doe v. Unum Life Insurance Co., Unum attempted to offset earned Social Security retirement benefits against the claimant’s long-term disability payments. The court disagreed, finding that the plan did not clearly allow such an offset, ruling in favor of the claimant. Similarly, Aisenberg v. Reliance Standard Life Insurance Co. highlighted a trend where courts scrutinize plan language carefully in disputes over offsets.
Takeaway for Claimants: Review your plan’s offset language and be prepared to challenge offsets that are not explicitly allowed under the policy.
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3. Procedural Reviews and the “Full and Fair” Standard
ERISA requires that insurers conduct a “full and fair review” of claims, a requirement that proved pivotal in multiple cases. Courts scrutinized whether insurers adhered to procedural standards, including timelines and balanced consideration of all medical evidence.
Case Example: In Cogdell v. Reliance Standard Life Insurance Co., the court found that Reliance’s procedural delays and inadequate consideration of the claimant’s long-COVID symptoms violated the full and fair review standard, ruling in favor of the claimant. This trend emphasizes the importance of procedural accuracy, as courts often penalize insurers for failing to meet these standards.
Takeaway for Claimants: Ensure timely submissions and seek assistance in preparing appeals, as procedural oversights can play a significant role in the outcome of your case.
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4. Complexity in Legal Standards Highlights the Need for Representation
These cases reveal the complexity of ERISA regulations and judicial standards, underscoring the importance of legal representation. In several instances, judges referenced nuanced federal regulations and legal precedents, indicating the difficulty for claimants to navigate these cases alone.
Case Example: In Wonsang v. Reliance Standard Life Insurance Co., the court noted procedural missteps that unfairly restricted the claimant’s ability to respond to Reliance’s findings. The judge referenced 29 CFR § 2560.503-1, a regulation outlining ERISA’s procedural requirements, illustrating the difficulty for claimants without legal expertise to identify such regulatory violations.
Takeaway for Claimants: Given the legal complexity, consulting an ERISA attorney can be invaluable, especially if procedural issues or specific plan language are involved.
Case-Specific Highlights
To illustrate these trends, here are summaries of some notable 2024 Virginia cases:
- Aisenberg v. Reliance Standard Life Insurance Co.: The court ruled in favor of the claimant, finding that Reliance Standard improperly offset retirement-related Social Security benefits instead of SSDI benefits.
- Paff v. Lincoln Life Assurance Co. of Boston: Lincoln Life won this case, as the court emphasized the need for objective medical evidence, which the claimant failed to provide adequately.
- Doe v. Unum Life Insurance Co.: The court ruled in favor of the claimant, stating that Social Security retirement benefits could not be offset against long-term disability payments unless explicitly defined as disability-related in the plan.
Advice for Claimants
If you’re preparing an ERISA long-term disability claim, keep these strategies in mind to improve your chances of success:
- Prioritize objective medical documentation: Include as much medical evidence as possible, such as diagnostic tests, clinical evaluations, and reports from specialists.
- Review and understand offset provisions: Familiarize yourself with your plan’s language around Social Security offsets to avoid unexpected reductions in benefits.
- Consult a legal professional: ERISA cases are procedurally complex, and an attorney can help ensure that procedural rights and evidentiary standards are fully leveraged in your appeal. Our highly experienced team offers 100% free consultations and Free Denial Letter reviews to put you in the right direction.
Conclusion
These 2024 cases suggest that Virginia’s federal courts are applying ERISA standards rigorously, often scrutinizing procedural compliance and the requirement for objective evidence. This trend may encourage insurers to follow tighter procedural standards, potentially benefiting claimants who ensure thorough documentation and legal support in their appeals.
You Need An Experienced Long-Term Disability Lawyer For Your Case
The most crucial part of your long-term disability claim happens before you ever step into a courtroom. If your administrative appeal is weak, incomplete, or lacking in key evidence and arguments, you’ll have little chance of winning in court. The moment your claim is denied, you need an experienced attorney on your side to guide you through the appeal process and set the stage for success.
At BenGlassLaw, we specialize in ERISA long-term disability claims. We know how to navigate the complexities of the administrative appeal, and we make sure every argument is made and every piece of evidence is submitted, so you have the strongest case possible when you need it most.
Don’t risk your future benefits by going it alone. Call us today for a free consultation, and let’s build your case from day one—because in ERISA long-term disability claims, that’s where cases are won.
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