An ERISA “Any Occupation” Denial Survives Despite Insurer’s Vocational Gaps

In Mead v. Life Insurance Company of North America, No. 8:24-cv-2756-TPB-AEP, 2026 WL 2444754 (M.D. Fla. Aug. 20, 2026), United States District Judge Tom Barber granted the insurer’s motion for summary judgment and denied the claimant’s cross-motion, upholding the termination of long-term disability benefits under an ERISA-governed group policy. The decision illustrates how the “any occupation” definition of disability, combined with a deferential standard of review, can sustain a benefit denial even where the administrative review contains acknowledged flaws.

What is the “any occupation” standard, and why does it matter in an ERISA disability claim?

Plaintiff worked for approximately 19 years as a package sealer/operator, a position classified as “heavy” work. After she stopped working in April 2020, the insurer approved short-term disability benefits and then long-term disability benefits under the policy’s “own occupation” standard. Under the ERISA plan, however, the definition of disability changed after 24 months. Beginning October 12, 2022, Plaintiff had to show she was unable to perform the material duties of any occupation for which she was, or could reasonably become, qualified based on her education, training, or experience. The insurer conducted a transferable-skills analysis, identified two sedentary occupations, and terminated benefits effective December 13, 2023. (Note: This shift from “own occupation” to “any occupation” is one of the most common turning points at which group disability claims are denied.)

What standard of review did the ERISA court apply?

The court applied the Eleventh Circuit’s multi-step framework from Blankenship v. Metropolitan Life Insurance Co., 644 F.3d 1350 (11th Cir. 2011). Because the plan’s Appointment of Claim Fiduciary granted the insurer discretionary authority to interpret the plan and determine eligibility, the court did not decide whether the denial was “de novo wrong.” Instead, it held that even assuming the decision was wrong, reasonable grounds supported it under the deferential arbitrary-and-capricious standard. Under that standard, the court must affirm a reasonable decision even if it would have reached a different result on its own.

Did the insurer’s failure to give its vocational reviewers the disability questionnaire doom the denial?

No. Plaintiff argued that the insurer failed to adequately consider her education, training, and experience because the disability questionnaire, though contained in the claim file, was never provided to the vocational specialists who performed the four transferable-skills analyses. The court agreed the questionnaire was omitted from all four analyses and stated that it did “not endorse” the insurer’s failure to supply a document sitting in its own file. The court nonetheless found the omission non-fatal. The administrative record otherwise documented Plaintiff’s educational and occupational background through the Social Security Administration transmittal and the vocational analyses themselves, and the final analysis characterized the identified occupations as entry-level positions requiring no specialized skills or training. Because the policy required consideration of education, training, and experience but not from any particular form, the omission did not render the determination arbitrary and capricious.

How did the court handle conflicting medical opinions on Plaintiff’s reaching limitation?

This was the closest issue. The record contained differing assessments of Plaintiff’s reaching capacity. Dr. Mahdy Flores assessed Plaintiff as able to reach only occasionally, while Dr. Alfred Becker found her arm use unrestricted and Dr. Louise Banks concluded the record did not support any reaching restriction. The court agreed with Plaintiff that there was a “tension” between Dr. Flores’s occasional-reaching limitation and the August 8, 2024, vocational analysis, which was instructed to use the most restrictive limitations yet still identified occupations requiring more reaching without explaining the inconsistency. The court found this did not control, however, because the review did not end there. The insurer obtained a later external review from Dr. Banks, who found no reaching restriction, and expressly relied on her assessment in the final determination. The court held that an administrator does not act arbitrarily merely because the record contains conflicting medical evidence, and may reasonably credit one physician’s opinion over another when its choice is rationally supported by the record.

Does it matter that one identified occupation was allegedly obsolete?

No. Plaintiff argued that the ampoule sealer occupation was obsolete and did not exist in sufficient numbers in the national economy. The court explained that, unlike the Social Security disability framework, ERISA does not require a plan administrator to establish that a particular number of jobs exists in the national economy. Moreover, the insurer had identified a second sedentary occupation, industrial-order clerk, so any problem with the ampoule sealer position did not undermine the overall determination.

Did the insurer’s failure to disclose two vocational analyses violate ERISA’s full-and-fair-review requirement?

The court assumed without deciding that the insurer should have disclosed the June 13 and July 16, 2024, transferable-skills analyses under 29 C.F.R. § 2560.503-1(h)(4)(i). It held any omission was not prejudicial. The earlier analyses were intermediate iterations that identified the same two occupations as the final August 8 analysis, which the insurer did disclose before its final decision. Because Plaintiff had the opportunity to respond to the disclosed analysis and advised that she had no additional evidence, the nondisclosure did not deprive her of a full and fair review.

Did the insurer’s conflict of interest change the outcome?

No. The insurer operated under a structural conflict because it both determined eligibility and paid benefits from its own funds. Under Blankenship, that conflict is a factor in the arbitrary-and-capricious analysis but does not alter the standard of review. Because Plaintiff identified no specific evidence that the insurer’s financial interest influenced the decision, and the record reflected multiple medical reviews, several vocational analyses, an additional external review, and an opportunity to submit evidence, the conflict did not render the determination arbitrary and capricious.

The court granted the insurer’s motion for summary judgment, denied Plaintiff’s cross-motion, and directed the Clerk to enter judgment in favor of the insurer and close the case.