Texas Court Upholds Unum’s Denial of ERISA Disability Benefits for Engineer with Syncope

In King v. Unum Life Insurance Company of America, No. H-25-1850, 2026 WL 1494238 (S.D. Tex. May 28, 2026), the United States District Court for the Southern District of Texas granted summary judgment to Unum Life Insurance Company of America and denied benefits to a refinery process engineer who claimed he could no longer work because of recurrent syncope. Applying de novo review, the court concluded that the evidence did not establish disability by a preponderance of the evidence under the terms of his ERISA-governed group disability plan.

What disability standard applied to the ERISA claim?

Plaintiff worked as a Staff Process Engineer at a Valero refinery and was covered under a group long-term disability policy issued by Unum. The policy defined disability for the first 24 months as being limited from performing the material and substantial duties of one’s regular occupation, measured by how the occupation is normally performed in the national economy rather than for a specific employer. Plaintiff alleged he suffered debilitating syncope that caused him to lose consciousness, and that climbing and driving, which he said were part of his work, would provoke additional episodes. Because the parties agreed Unum lacked discretionary authority, the court reviewed the denial de novo and applied the same standard Unum would have applied in deciding whether benefits were owed.

Why did the court find the medical evidence insufficient?

The court identified three reasons the evidence did not support the claim. First, Plaintiff had worked for years after his syncope diagnosis. He first saw a cardiologist for syncope in December 2016 and tested positive for vasovagal syncope that same month, yet continued working at Valero until May 2023. His own claimant statement initially anticipated a return to work in October 2023. The court found this post-diagnosis work history undercut the assertion that his condition prevented him from performing his job.

Second, the court found that Plaintiff’s conduct did not match the severity of the disability he described. His treating cardiologist repeatedly instructed him to go to the emergency room if symptoms worsened, but he had no documented emergency room visits or hospitalizations for syncope after he stopped working. He did not see a neurologist despite a referral. The court also noted inconsistencies between Plaintiff’s 2023 reports that he was walking daily, weightlifting, using a stationary bike, and helping with household tasks, and his later 2024 reports that he could not walk more than thirty minutes, stand for ten to fifteen minutes, or drive. The court observed that the reported decline coincided with the progress of his claim and lacked supporting medical documentation.

Third, Unum’s reviewing medical professionals provided ample support for their conclusions. Three reviewers concluded that the medical evidence did not support the claimed restrictions and limitations, citing the absence of documented syncopal events after the alleged disability date, normal examination findings, the absence of structural heart disease, and inconsistencies between Plaintiff’s self-reported symptoms and the objective record.

How did the court treat the self-reported and corroborating evidence?

The court found that the statements from Plaintiff, his family, and his friends described severe symptoms but were entirely self-reported. It explained that those reports did not gain credibility simply because the treating cardiologist recorded them in his notes, many of which followed telemedicine visits without physical examination. The treating cardiologist’s explanations of restrictions and limitations were sparse, he did not respond to Unum’s request for clinical information after its preliminary assessment, and his post-denial restrictions form offered little explanation for his conclusions. The court also noted that Plaintiff did not seek an independent medical examination to corroborate his reported symptoms.

What was the outcome of the ERISA benefits dispute?

The court held that Unum’s medical professionals considered the full record and reasonably concluded that the evidence did not support the claimed restrictions and limitations, and that this conclusion was supported by the record. The court granted Unum’s motion for summary judgment, denied Plaintiff’s cross-motion, and entered final judgment in Unum’s favor.