Mitchell v. Eastman Kodak Co.
Beginning in the fall of 1988, Mr. Mitchell began experiencing persistent sore throats, coughs, fever, and extreme fatigue. At first, his first treating doctor was unsure what was causing his symptoms. However, he was eventually diagnosed with CFS. CFS is an illness that is characterized by intermittent flu-like symptoms and chronic fatigue. Although it is recognized as a severe disability, it does not have a known infectious cause.
The Claim, Denial, and Lawsuit
Because of the chronic fatigue, Mr. Mitchell had to stop working. He filed his claim for long-term disability benefits. Even though Mr. Mitchell submitted his medical records and several statements from his physicians that supported his symptoms and condition, Metropolitan denied his claim. Kodak reviewed the denial and agreed with Metropolitan because he failed to provide “objective medical evidence” that showed he was unable to work in any gainful occupation.
Mr. Mitchell then filed a lawsuit. The trial court agreed with Mr. Mitchell that he was totally disabled and unable to work in any gainful occupation. Kodak appealed.
The Appellate Court’s Review
On appeal, the Third Circuit concluded that “objective medical evidence” meant clinical evidence of the cause of the disabling condition. The Court held that Kodak was wrong to require such evidence because (1) the Plan did not require it; and (2) it was widely accepted that there was no laboratory test that identified the cause of CFS.
Moreover, upon examining the record, which included Mr. Mitchell’s medical records and the statements from his physicians, the Third Circuit agreed with the trial court and held that Mr. Mitchell was totally disabled and entitled to benefits.
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