In Cameron v. Sun Life Assurance Company of Canada, 2:21-cv-02092 JLS (AFM) (C.D. Cal. Nov. 2, 2022), California Central District Judge Josephine L. Stanton determined on de novo review that Plaintiff Duane Cameron established by a preponderance of evidence that he was disabled from his own occupation due to cardiac symptoms and occupational stress, and awarded long term disability benefits under the Employee Retirement Income Security Act of 1974 (“ERISA”).
Before his disability, Mr. Cameron had been working as a radiology administrator at USC Verdugo Hills Hospital. He had taken the maximum duration Short Term Disability leave due to chest pain and high blood pressure starting in August 2019, after being hospitalized for chest pain aggravated by stress. Although he did not undergo surgery or demonstrate particularly severe or uncontrolled symptoms in subsequent months, his doctors continued to recommend that he remain off work through January 2020. His doctors documented that job-related stress was likely contributing to the progression of his coronary disease and that returning to work would pose a risk to Mr. Cameron’s health. The court gave considerable weight to the opinion of Mr. Cameron’s treating doctor, Dr. Klein, who consistently and repeatedly assessed him to be disabled due to a combination of his cardiac condition and occupational stress. The court noted that Dr. Klein had not merely provided check-the-box assessments but had written lengthy and detailed narrative form office visit notes supporting his opinion, which made it especially persuasive.
Sun Life’s medical reviewers argued that if stress were a real factor, there should have been documentation of behavioral health treatment such as counseling or stress management interventions. The court, however, found this argument was based on an assumption, and nothing in the record indicated that behavioral health should have been part of Mr. Cameron’s treatment. The court found that the reviewing doctors’ opinions failed to consider the combination of both cardiac and stress factors in determining Mr. Cameron was not disabled. The court also considered that multiple case precedents supported the proposition that cardiac issues can combine with work-related stress to produce a disabling condition. The court thus awarded long term disability benefits to Mr. Cameron based on the supporting documentation through January 29, 2020.
Medical notes from Dr. Klein on January 29, 2020 documented that Mr. Cameron was choosing to retire from his job due to cardiac issues and work related stress, but there was no discussion of cardiac symptoms requiring intervention at that appointment nor in the preceding five months. Although the court acknowledged that Dr. Cameron’s decision to retire likely factored in the cardiac risk of working a stressful job, there was no discussion in the medical documentation of a then-current disabling condition that might have justified continued receipt of benefits beyond January 29, 2020. Approximately five weeks later, in March 2020, Mr. Cameron experienced another health crisis involving pain and shortness of breath which resulted in coronary angioplasty surgery. The court acknowledged that Mr. Cameron was no doubt disabled in March 2020, and even Sun Life’s reviewers acknowledged he would have been disabled for several weeks following surgery. Nonetheless, the court found that during the interim period from the end of January through beginning of March 2020, Mr. Cameron had already retired, the group policy was no longer in force, and there was no persuasive evidence that he was unable to perform the duties of his position.
The court concluded that Mr. Cameron’s entitlement to benefits ended after January 29, 2020. Under certain “limited circumstances” the court can consider evidence outside the administrative record. Here, the court declined to consider additional extrinsic evidence offered by Mr. Cameron related to the time period in and after September 2020, explaining that records related to this later time period were not relevant to determining whether his benefits entitlement ended in January 2020.
As this case demonstrates, it can be difficult to win an ERISA long term disability benefit claim. If Sun Life has denied your disability insurance claim, contact us for assistance.
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