Sedentary Work Defined for ERISA Disability Cases
Sedentary work was recently addressed in a court case decided in the California Court of Appeals. The Court gave a clear definition of sedentary work as it relates to an ERISA disability claim. In this case, the disabled man challenged the lower court’s denial of his long term disability insurance benefits claim based on their definition of a sedentary job. This case provides a strong analysis for whether a totally disabled person can continue to do sedentary work when they are unable to sit for a lengthy period of time.
Sedentary work as defined by the Dictionary of Occupational Titles (DOT) involves sitting most of the time, with brief periods of walking or standing. For someone who cannot sit more than a couple hours at a time, this definition would preclude them from working an average workday in a sedentary job.
An average workday is eight hours. If the definition for a sedentary job is sitting most of the time, then common sense would say a person who does sedentary work would be required to sit for about six hours in total, out of an eight hour work day.
For example, a desk job in a quiet office is categorized as sedentary work. Therefore, by definition, the person working that job would be required to sit at their desk the majority of time they are at work. But, if the person’s doctors all agreed that, due to their injuries or medical conditions, they could only sit for four hours at a time, then that person could not work a desk job or any sedentary job.
The California appeals court held that someone who could not sit for more than four hours could not work a sedentary job. In fact, many courts dealing with ERISA claims have held that someone who can only sit for about four hours at a time is not capable of sedentary work.
This case is a good example of how important it is to understand the various job categories and what they mean, when applying for long term disability insurance benefits. Having an experienced long term disability insurance attorney who is familiar with ERISA claims can help ensure you are given a fair review of your claim. If you feel like your claim was improperly analyzed by your insurance company, contact Dabdoub Law Firm for an evaluation of your insurance disability benefits case.