Even though the California teacher suffered from Chronic Lyme Disease and numerous other conditions, Standard Insurance Company (“Standard”) still denied her claim for long-term disability (“LTD”) benefits.
Background
Ms. Entz suffered from various medical issues since she was a child, worsening as she got older. Despite the numerous medical conditions, Ms. Entz started feeling particularly ill in 2013.
After almost two years of doctor visits and testing, Ms. Entz was diagnosed with Chronic Lyme Disease. Even with the diagnosis, numerous other conditions and symptoms persisted, from arthritis to hypothyroidism to gastrointestinal issues. Three of her treating doctors believed she was disabled and unable to work.
The Claim and Denial
Ms. Entz filed her claim for long-term disability in August 2015. She listed Lyme Disease and “multi-system failures” as the reason for her disability. Her doctor corroborated the diagnosis and also listed several other diagnoses and conditions that were reasons Ms. Entz was unable to work.
However, Standard denied her claim because there was not enough medical evidence to support that Ms. Entz suffered from a specific illness. In addition, Standard did not accept Lyme Disease as a valid diagnosis.
Court’s Review of Ms. Entz’s Claim
Standard argued that the diagnosis of Lyme Disease, or Chronic Lyme Disease, was medically questionable. However, the trial court quickly rejected this argument.
Rather, the court stated Ms. Entz’s symptoms should be looked at in the context of her entire medical history. Standard’s sole focus on whether there was a test to conclusively establish Lyme Disease while ignoring her numerous symptoms was improper. Instead, Ms. Entz’s disability should have been assessed in light of her capacity to work as a teacher given her symptoms.
Looking at Ms. Entz’s medical file as a whole, the trial court determined Ms. Entz was totally disabled and entitled to benefits under the terms of the policy.
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