Montana Court Rules Against Sun Life’s Denial of Disability Benefits: Objective Evidence Not Required to Prove Chronic Pain

Background

Paula Maulolo held three positions as an Internal Medicine Residency Program Administrator, Organizational Development Consultant, and Medical Education Specialist. She also owned a jiujitsu dojo with her husband.

Chronic back and leg pain took over Maulolo’s life and restricted her ability to work. After several accommodations at work and numerous treatments with doctors, Maulolo applied for long term disability with Sun Life.

Sun Life rejected Maulolo’s claim stating that the “medical evidence does not support” that she was disabled from performing her own occupation. Maulolo appealed Sun Life’s decision with medical records from ten additional providers. Sun Life again denied Maulolo’s appeal claiming she failed to prove her disability during the elimination period—the time period between when she stopped working and when her LTD benefits would begin.

The Court’s Decision

The Montana Court found that the medical evidence supported Maulolo disability. Specifically, the Court held that the evidence showed she was no able to perform the duties her job, as required under the disability insurance policy.

The Court also rejected Sun Life’s argument that Maulolo’s record lacked any objective evidence of functional impairment. The Court noted that in chronic pain cases, Courts have found objective evidence is not required. Thus, the Court held that a lack of objective evidence in not a good enough reason to deny disability benefits.

Disability Insurance Companies Have Lawyers. Shouldn’t You?

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