Key Takeaways
- A Washington manufacturing manager developed chronic fatigue, brain fog, and headaches after receiving the COVID-19 vaccine, leaving him unable to perform his job.
- Unum denied his long-term disability claim, insisting the medical evidence did not objectively prove disability.
- The federal court rejected Unum’s reasoning, ruling that subjective evidence of illness is valid when the policy does not specifically require objective proof.
- Dabdoub Law Firm has a proven track record of helping people nationwide fight wrongful disability insurance denials, especially when insurers demand unfair proof of disability.
Background of the Case: Illness Post-COVID-19 Vaccination
Ryan Waldron worked as a production line manager at a manufacturing plant in Washington, where he oversaw 20–25 employees and spent most of his 60–70-hour workweek on his feet managing operations. In May 2021, he received his first dose of the COVID-19 vaccine. While the initial side effects subsided, he soon developed persistent fatigue, dizziness, headaches, brain fog, and double vision. These symptoms prevented him from performing even routine tasks, much less the physically demanding duties of his job.
Waldron sought medical treatment from multiple providers, including family practitioners, neurologists, infectious disease specialists, the Mayo Clinic, and physical therapists. His doctors consistently documented his limitations, though diagnostic testing such as MRIs and bloodwork failed to provide a clear explanation. Some providers believed his condition resembled long COVID, while others suggested an inappropriate immune response to the vaccine.
After receiving short-term disability benefits, Waldron applied for long-term disability (LTD) coverage under his employer-sponsored plan administered by Unum Life Insurance Company of America (Unum). Unum denied his long term disability claim, asserting that there was insufficient objective medical evidence to prove he was disabled. Waldron appealed, but Unum upheld its denial. He then filed suit under the Employee Retirement Income Security Act (ERISA).
The Court’s Review Under ERISA
Because Waldron’s disability insurance policy was governed by ERISA and the policy did not contain discretionary langauge, the court conducted a de novo review, meaning it independently evaluated whether he met the plan’s definition of disability. Under the LTD policy, an employee is disabled if:
- They cannot perform the material and substantial duties of their regular occupation due to sickness or injury, and
- They suffer at least a 20% loss in earnings as a result.
Notably, the policy did not require claimants to provide “objective” evidence of disability. The court emphasized that insurers cannot invent an objective-evidence requirement if the policy language does not include one.
Medical Evidence and Credibility
The Washington District Court found Waldron’s treating doctors credible. Over months of evaluations, they consistently reported symptoms that limited him from working. Physical therapy notes documented that even minimal exertion triggered debilitating flares. A neuropsychological evaluation confirmed cognitive deficits, such as slowed processing and memory problems, while also ruling out malingering or psychiatric causes.
Although Unum’s in-house physicians claimed Waldron’s test results were “normal,” the court explained that many disabling conditions—such as chronic fatigue syndrome, fibromyalgia, and long COVID—do not show up on objective tests. Courts in the Ninth Circuit have long held that self-reported symptoms, when supported by physician observations, are valid evidence of disability.
The Court’s Decision
Judge Tiffany M. Cartwright ruled that Waldron had proven by a preponderance of the evidence that he was disabled under the terms of the Unum LTD policy. The court granted his motion for judgment and denied Unum’s cross-motion, ordering the insurer to pay LTD benefits.
The court’s reasoning was clear:
- Subjective symptoms must be considered when no reliable objective test exists.
- Treating physicians’ assessments, based on repeated examinations, carry weight even if diagnostic results are inconclusive.
- Unum’s reliance on file reviews by non-examining doctors could not overcome the consistent medical evidence supporting disability.
Why This Case Matters for Disability Insurance Claimants
This ruling is important for anyone facing a disability insurance denial involving conditions that lack definitive objective tests. Insurers often reject claims by insisting on lab results or imaging studies that simply do not exist for conditions like:
- Chronic fatigue syndrome
- Long-COVID
- Fibromyalgia
- Migraine and chronic headache disorders
The Waldron case reinforces that courts will not allow insurers like Unum to impose proof requirements beyond what the policy states. If your policy does not demand objective evidence, your own reports of symptoms, when supported by medical documentation, are valid proof of disability.
How Dabdoub Law Firm Helps
At Dabdoub Law Firm, we focus exclusively on disability and life insurance claims. We know the tactics insurers use to deny claims and how to beat them in court. Like Waldron, many of our clients suffer from conditions that are difficult to “prove” with medical imaging or lab results. Our attorneys have successfully litigated these cases, securing benefits for clients across the country.
- We handle cases nationwide.
- We have taken on every major insurance company, including Unum, Lincoln, Hartford, and MetLife.
- We are a litigation powerhouse with a proven record of success in federal court.
- Disability and life insurance claims are all we do.
If your disability or life insurance claim has been denied, you don’t have to face the insurance company alone. We can help you fight back and recover the benefits you deserve.
Disclaimer: Dabdoub Law Firm did not handle this case.