Subjective Job Demands Don’t Override General Objective Parameters
A healthcare attorney who was the beneficiary of an Employee Retirement Income Security Act (ERISA) long term disability insurance policy filed a complaint against the plan administrator alleging wrongful denial of benefits. The attorney, who suffered from migraine headaches, argued the administrator never evaluated whether she could perform the specific duties of her job such as meeting deadlines, handling stress, prolonged computer use and the intellectual challenges of handling complex situations. The Fifth Circuit affirmed holding substantial evidence supported the denial of benefits. The court took no issue with the administrator relying on its own treating physicians’ reports detailing absence of the beneficiary’s functional impairments over her subjective evidence that she experienced migraines.