California Court Denies ERISA Disability Benefits Despite Undisputed Tinnitus and Depression Diagnoses

In Camp v. Lincoln National Life Insurance Company, No. 25-cv-06199-AMO, 2026 WL 2608200 (N.D. Cal. Sept. 3, 2026), Judge Araceli Martínez-Olguín of the United States District Court for the Northern District of California denied Plaintiff’s motion for judgment and granted Lincoln National’s motion for judgment under Federal Rule of Civil Procedure 52, upholding the denial of long-term disability benefits under an ERISA-governed group plan. Reviewing the claim de novo, the court concluded that Plaintiff failed to prove by a preponderance of the evidence that his tinnitus, hearing loss, and depression rendered him unable to perform his own occupation.

What did Plaintiff have to prove under the ERISA plan?

Plaintiff worked as an account executive at Yelp when he stopped working in January 2024, reporting left-ear tinnitus that he said caused insomnia, difficulty concentrating, and depression. His group policy defined disability, during the elimination period and the following 24 months, as being unable to perform with reasonable continuity the substantial and material acts of his own occupation. Because the parties agreed Lincoln National lacked discretionary authority, the court reviewed the denial de novo, meaning Plaintiff carried the burden of establishing disability by a preponderance of the evidence. The court emphasized that the mere existence of a diagnosis is not proof of disability; Plaintiff had to show that his conditions actually impaired his ability to work.

Why did the medical evidence fail to establish a physical impairment?

The court found Plaintiff did not demonstrate that his tinnitus and asymmetrical hearing loss prevented him from performing his sedentary occupation. Lincoln National’s reviewing otolaryngologists, Dr. Song and Dr. Zandifar, concluded Plaintiff could work with restrictions limited to avoiding unprotected heights, heavy machinery, and loud environments, along with the ability to use hearing aids and a compatible phone. Plaintiff’s own treating physician, Dr. Rahhal, agreed with those restrictions. Lincoln National’s vocational expert determined that none of these restrictions precluded Plaintiff’s own occupation, which did not require bilateral hearing, work at heights, or operation of machinery. Because Plaintiff offered no countervailing vocational evidence, the court found he failed to establish a disabling physical impairment.

Why did the court reject the claim of cognitive and psychiatric impairment?

The court concluded the record lacked evidence that tinnitus impaired Plaintiff’s concentration or cognitive function. Plaintiff’s own activities questionnaire reported that he performed all activities of daily living independently, managed his finances, and continued communicating with others. His treating physician’s own functional assessment indicated only “no/mild loss” across most cognitive categories. On the psychiatric side, both of Lincoln National’s reviewing experts, Dr. Morthala and Dr. Lipschutz, found no clinical support for functional impairment. The court noted that the disability claim rested largely on Plaintiff’s self-reports rather than documented mental status examinations, and held that self-reported symptoms, unsupported by clinical findings, do not establish a disabling condition.

Did prior approval of short-term disability benefits help the claim?

No. Plaintiff argued that Lincoln National’s payment of short-term disability benefits supported his entitlement to long-term benefits. The court rejected this, explaining that the short-term disability plan was a separate contract with its own terms and was not part of the administrative record. The court distinguished authority involving a later denial under the same plan, holding that prior approval under a distinct short-term policy did not establish entitlement under the long-term disability Policy at issue.

What does this ERISA decision mean for disability claimants?

Camp is a reminder that under de novo review, the burden rests squarely on the claimant, and a diagnosis alone will not carry it. The court repeatedly distinguished between having a condition and being functionally impaired by it. Where the record consists largely of self-reported symptoms without corroborating examination findings, restrictions, or vocational evidence, even genuine conditions like tinnitus and depression may not support a benefits award. Claimants pursuing group long-term disability claims should ensure their providers document specific, occupation-related functional limitations, not just diagnoses.