Court Upholds Unum’s Denial of Long-Term Disability Benefits for River Pilot Claiming Long COVID Disability

In Hans v. Unum Life Insurance Company of America, No. CV 25-3595, 2026 WL 116487 (E.D. Pa. Jan. 15, 2026), the U.S. District Court for the Eastern District of Pennsylvania upheld Unum Life Insurance Company of America’s denial of long-term disability (“LTD”) benefits to a river pilot who claimed he was disabled by long COVID, concluding the denial was reasonable and supported by substantial evidence under ERISA’s deferential arbitrary-and-capricious standard of review.

The plaintiff, a river pilot, stopped working in May 2023 after experiencing symptoms he attributed to long COVID, including fatigue, tachycardia, neurological symptoms, and post-exertional malaise. He applied for LTD benefits under his employer’s plan, which granted Unum discretionary authority to determine eligibility and defined “regular occupation” as the occupation as normally performed in the national economy. The plan also required the claimant to be continuously disabled throughout a 360-day elimination period.

Unum denied the claim, finding the plaintiff was not precluded from performing the material and substantial duties of his regular occupation before the elimination period expired. In doing so, Unum relied on multiple internal medical reviews, vocational analyses classifying the plaintiff’s occupation as a “ship pilot” requiring only light work, and evidence showing improvement in the claimant’s condition and largely normal objective findings. Unum rejected the claimant’s contention that his job should be treated as a composite occupation involving heavy physical demands and discounted opinions from treating providers and a post-elimination-period functional capacity evaluation.

On cross-motions for judgment on the administrative record, the court applied abuse-of-discretion review and affirmed Unum’s decision. The court held that Unum reasonably determined the claimant’s “regular occupation” based on how it is performed in the national economy, as expressly required by the policy, and was not required to adopt a composite occupation theory. The court further held that Unum permissibly credited its reviewing physicians over treating providers, explaining that ERISA does not impose a treating physician rule. Although long COVID lacks definitive objective diagnostic testing, the court emphasized that Unum could reasonably require objective evidence of functional limitations, not merely a diagnosis.

The court also rejected the claimant’s argument that Unum’s structural conflict of interest rendered the denial arbitrary and capricious. While acknowledging Unum’s dual role as claim evaluator and payor, the court found no procedural irregularities and concluded the conflict was a neutral factor that did not tip the balance in the claimant’s favor.

Accordingly, the court granted judgment in favor of Unum and denied the claimant’s request for LTD benefits, reinforcing the broad discretion afforded to plan administrators where plan language is clear and the administrative record supports a reasoned decision.

Practice Pointer

This decision underscores the uphill battle claimants face when challenging LTD denials involving long COVID under deferential arbitrary-and-capricious review. Even where a condition lacks definitive objective diagnostic testing, plan administrators may reasonably require objective evidence of functional impairment—particularly during the elimination period—and may discount post-elimination functional capacity evaluations if they are not tied to contemporaneous medical findings. The case also highlights the continued importance of plan language defining “regular occupation” as work performed in the national economy, which can foreclose arguments based on the claimant’s real-world job demands or composite occupation theories.