Crystal Williams v. UNUM Life Insurance Company of America
Lauren A. Welch won a victory in favor of UNUM Life Insurance Company of America in the case entitled Crystal Williams v. UNUM Life Insurance Company of America, in the U.S. District Court, Western District of Louisiana.
The long-term disability (LTD) policy issued by UNUM had a definition of “disabled” that was divided into two phases: (1) the first twenty-four months of payments, which considered the insured’s ability to perform the material and substantial duties of her regular occupation; and (2) after the first twenty-four months, which considered the insured’s ability to perform the duties of any gainful occupation for which she was reasonably fitted by education, training or experience. UNUM paid LTD benefits to the plaintiff for the first twenty-fours months of impairment, under the “regular occupation” phase of the policy’s definition of disabled and terminated benefits thereafter, under the “any gainful occupation” phase of the definition. The District Court noted that UNUM’s transferable skills analysis identified sedentary occupations for the plaintiff and that the plaintiff presented no evidence that she was incapable of performing said occupations. The District Court held that, despite the fact that the plaintiff’s treating physicians had indicated that she could not work in any capacity, UNUM’s in-house physicians and vocational rehabilitation staff disagreed and concluded that, based upon the evidence in the administrative record, the plaintiff could perform sedentary work. The District Court granted summary judgment in favor of UNUM and dismissed Plaintiff’s claims, with prejudice.