ERISA Long-Term Disability Denial Reversed: Utah Court Remands Equitable’s Termination for Ignoring Evidence of Claimant’s Mental Condition

In Pickering v. Equitable Financial Life Insurance Company of America, 2026 WL 2606603 (D. Utah Sept. 3, 2026), United States District Judge Tena Campbell resolved cross-motions for summary judgment in an ERISA action challenging the termination of long-term disability benefits, denying the insurer’s motion, granting the claimant’s motion in part, and remanding the claim to Equitable for further consideration. Plaintiff sought long-term disability benefits under a group employee welfare benefit plan sponsored by his former employer and insured by Equitable, which served as claims administrator. Equitable initially granted benefits effective May 2022, then terminated them in May 2024 when the Policy’s “Any Occupation” standard replaced the “Own Occupation” standard at the twenty-four-month mark. The parties agreed the court would apply de novo review because the parties treated the Policy’s discretionary-authority provision as unenforceable, and the court did not need to decide whether Utah’s ban on discretionary language applied.

Does a job that requires some additional training count as an occupation for which a claimant is “qualified” under an “Any Occupation” standard?

Yes. Equitable’s termination relied on an Employability Analysis Report that used a computerized job-matching system and identified two occupations that were a “fair” match and twenty-two that were a “potential” match for Plaintiff, each requiring some additional training on tools and materials. Plaintiff argued that because the identified occupations required training, he was not “qualified” for them and therefore satisfied the “Any Occupation” standard. The court rejected that reading. It found the reasoning of Jackson v. Hartford Life & Accident Insurance Co., 2024 WL 3218236 (S.D. Ohio June 28, 2024), compelling, emphasizing that the Policy’s definition, qualification “by education, training or experience,” is disjunctive, so a claimant qualified by education or experience alone satisfies the definition even without prior training. The court declined to follow Bishop v. Aetna Life Insurance Co., 163 F. Supp. 3d 443 (E.D. Ky. 2016), and Curtis v. Hartford Life & Accident Insurance Co., 64 F. Supp. 3d 1198 (N.D. Ill. 2014), reasoning that treating any amount of required training as disqualifying would defy the common-sense meaning of being qualified for a job. Because the Report excluded occupations with a Specific Vocational Preparation level of 4 or above and the remaining roles required only thirty days to three months of short-term on-the-job training, the court found the required training reasonable and rejected Plaintiff’s timing and skills-estimation arguments as extensions of the same rejected premise. The court also declined to require the Report to account for Plaintiff’s age, noting that Social Security regulations do not govern ERISA proceedings.

Can an administrator deny disability benefits after overlooking record evidence of the claimant’s mental condition?

No, at least not on this record. Plaintiff argued that Equitable’s denial rested on a Medical Case Manager review that stated no cognitive testing had been completed and that the records contained no mention of mental health treatment or care, even though the record repeatedly addressed Plaintiff’s anxiety disorder and associated treatment and medications. The court agreed that the review missed that evidence, and it noted that the Medical Case Manager had partly rejected the opinion of one of Plaintiff’s doctors on the basis of that purported absence. Citing the full and fair review requirement and Tenth Circuit authority that administrators may not arbitrarily refuse to credit reliable treating-provider evidence, the court found the process procedurally deficient. Because it was unknown what conclusion Equitable would reach after considering the overlooked evidence, the court remanded rather than awarding benefits.

Did the claimant forfeit his mental-condition argument by raising it for the first time in litigation?

No. The court explained that the Tenth Circuit bars unexhausted ERISA claims but has not extended that rule to subsidiary arguments urged in support of a claim that was itself fully exhausted. Plaintiff’s mental-condition argument was a permissible subsidiary argument supporting his exhausted claim. The court also noted that Equitable already had knowledge of the issue, because one of Plaintiff’s doctors had told Equitable, in response to its own inquiry, that Plaintiff’s anxiety, cognitive status, and social skills impaired his ability to perform full-time sedentary work, and Equitable issued its Report six days later.

Does the Policy’s twenty-four-month mental-illness limitation bar further benefits when the claimant already received twenty-four months under a physical-disability standard?

No. Equitable argued that Plaintiff had exhausted the Policy’s lifetime twenty-four-month cap on benefits for disabilities “because of” mental illness. The court disagreed. When Plaintiff applied, he identified only congestive heart failure, COPD, and hypertension, so his qualifying disability during the initial “Own Occupation” period was not “because of” any mental condition. Reading “because of” to require that a mental illness play a causal role in the disability determination, the court held that Plaintiff had not exhausted the potential twenty-four-month period of benefits tied to mental illness.

Because remand rather than an award of benefits was the appropriate remedy, the court denied Plaintiff’s requests for prejudgment interest and attorneys’ fees as premature. It reversed Equitable’s denial, remanded for further proceedings, and retained jurisdiction with the case administratively closed pending completion of the review on remand.