An Illinois federal court of appeals ruled that the lower federal district court erred when it failed to consider a Systems Analyst’s inability to sit at his desk for 8 hours a day and his inability to perform the cognitive requirements of his job.
Background
Scott Scanlon, a U.S. Army veteran with a history of chronic pain and sleep disorders, worked as a Systems Analyst at McKesson Corporation. In 2017, he went out of work due to his medical conditions and submitted a claim for long-term disability (“LTD”) benefits to Life Insurance Company of North America (“LINA”).
LINA denied Mr. Scanlon’s LTD claim and later denied his appeal after completing 2 medical reviews. Consequently, Mr. Scanlon filed suit against LINA under ERISA in federal court.
The Lower & Appeals Courts’ Decisions
The lower court found Mr. Scanlon suffers from chronic orthopedic issues and sleep disorders that cause him pain and impact his daily life. Nevertheless, the lower court ruled that Mr. Scanlon was not entitled to LTD benefits because he did not provide evidence that he is unable to perform the material duties of his job. Thus, the lower court ruled in LINA’s favor. Mr. Scanlon then appealed to Federal Appellate Court.
The appeals court reviewed the evidence Mr. Scanlon submitted on appeal, and found that he had provided extensive medical records, including examination reports and letters from his treating providers. He also provided a functional capacity evaluation (“FCE”) performed by a licensed physical therapist confirming he cannot perform work duties.
Additionally, the appeals court noted Mr. Scanlon’s sedentary job required that he perform not only physical, but cognitive tasks as well.
Based on its review of the evidence, the appeals court concluded the lower court failed to properly consider the results from Mr. Scanlon’s FCE, which determined he could not work full-time as he cannot sit for more than 3 hours per day due to his chronic pain.
The appeals court found this evidence clearly showed that he is unable to perform his job, which requires that he sit at a computer for 8 hours a day. Further, the appeals court also concluded that the lower court erred when it failed to consider the effect Mr. Scanlon’s chronic sleep disorder had on his ability to perform the cognitive requirements of his job.
This case is important in that it highlights the significance of providing evidence to support your inability to perform both the physical and cognitive requirements of your job. Having an expert in disability insurance law on your side will help to make sure you are providing the best possible evidence to support your claim.
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