A federal court ordered LINA to pay long term disability benefits to a Washington engineer with physical and mental health conditions.
Reynolds’ Disability Forces Her to Stop Working
Lucy Reynolds was diagnosed with numerous health conditions over the years, including depression, anxiety, post-traumatic stress disorder (“PTSD”), fibromyalgia, migraine headaches, asthma, hypothyroidism and multiple sclerosis (“MS”). From 2006 to 2014, she worked as a full-time engineer for Affymetrix before asking that her hours be reduced to thirty hours per week due to fatigue, pain, anxiety issues, and other related symptoms caused by her comorbid health conditions.
Despite receiving the requested reduction in hours, Reynolds was forced to stop working in November 2015 when she was no longer able to keep up with the job demands of her high-stress occupation.
The Disability Policy and Reynolds’ Claims for Benefits
During her time with Affymetrix, Reynolds was a participant in an employee benefit plan (the “Policy”) issued by LINA and governed by the Employee Retirement Income Security Act of 1974 (“ERISA”). In part, the Plan provides for both Short Term Disability (“STD”) and Long Term Disability (“LTD”) benefits, includes different definitions of “Disabled” from one’s “Regular Occupation” and “Disabled” from “Any Occupation”, and states that proof of loss must be given to LINA within 90 days after the date of the loss for which a claim is made.
In October 2019, Reynolds initiated a claim with LINA but was denied due to incorrectly listing an October 2012 date as her date of disability. In April 2020, she informed LINA that she was seeking both STD and LTD benefits from the date she stopped working in November 2015 to the present, as a result of her MS.
On May 5, 2020, LINA advised Reynolds of the Policy’s requirement to provide proof of loss within 90 days and required her to explain why her claim submission was late. Reynolds stated that she was unaware of her right to claim benefits when she was forced to leave her job.
Although LINA went on to approve and pay all of Reynold’s STD benefits, it denied her LTD claim on the basis that she failed to satisfy the Policy’s definitions of Disabled from November 21, 2015, and beyond, in order to receive LTD benefits. After LINA denied Reynolds’ appeal, she exercised her right to file a lawsuit in federal court.
The Court’s Decision
The court ruled that Reynolds was entitled to judgment in her favor and payment of benefits under both the “Regular Occupation” and subsequent “Any Occupation” standards of the Policy. Specifically, the court concluded that since LINA approved her STD benefits, which had the same definition of disability for the first 24 months as the LTD policy, then it would be logical she meet the definition of disability for the first 24 months of LTD benefits.
The court was persuaded that Reynolds’ medical conditions had not improved, and she continued to suffer from ongoing disabling illnesses. It also found that although approval of her Social Security Disability benefits is “not dispositive,” it was nevertheless convincing evidence that Reynolds’ numerous impairments leave her unable to perform the duties of “Any Occupation.”
For these reasons, the court held that Reynolds met her burden of establishing entitlement to LTD benefits and ordered LINA to not only pay her claim through the date of the decision, but to continue paying them until the Policy’s maximum benefit duration absent a showing that she is no longer disabled within the meaning of the Policy.
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