The Northwestern Mutual Life Insurance Company denied the long term disability claim of a man who was unable to sit for more than four hours after suffering back injuries. A California appellate court found Northwestern Mutual’s denial was unlawful. The claimant, Avery Armani, filed a lawsuit against Northwestern Mutual under ERISA because his back injuries left him disabled and unable to work in his sedentary job.
The insurance company’s claim file -also known as the administrative record, included medical opinions from his treating physician and chiropractors that Armani could not sit for more than four hours per day. Also included in the record was a description of his job, which was described as sedentary most of the time.
As part of the claim process, Northwestern Mutual did their own evaluation. Their doctor determined that Armani is capable of sedentary work without any limitations or restrictions. Next, their vocational specialist determined there were three sedentary jobs Armani could perform.
Under the long term disability plan, Armani would be entitled to disability benefits for the first 24 months if he is disabled from his own occupation. After that 24 month period, he must be disabled from all occupations. Northwestern Mutual determined that he is capable of working in his own occupation, a sedentary job. Armani filed a lawsuit under ERISA but the lower court agreed with Northwestern Mutual, holding that even though he could only sit for four hours, he was able to work a sedentary job. However, Armani then appealed the denied long term disability claim.
The court of appeal agreed with Armani and found that the lower court was wrong in its analysis of what a sedentary job requires. The appeals court noted that although it had not dealt with this issue before, other courts handling ERISA disability claims has defined sedentary work as requiring the ability to sit most of the time.
Those courts explained that, in an eight hour workday, a person is required to sit about six hours in total. The appeals court held that someone who cannot sit for more than four hours cannot work an eight hour workday in sedentary job. The denied long term disability claim was reversed and Armani received the benefits he was due.
