District Court Grants Plaintiff’s Motion for Judgment in ERISA Disability Dispute Highlighting Unum’s Selective Review of Evidence

In Jessica L. v. Unum Life Insurance Company of America, No. 24-CV-02046-RFL, 2025 WL 1739595 (N.D. Cal. June 24, 2025), on cross-motions for judgment pursuant to FRCP Rule 52, California Northern District Judge Rita F. Lin granted Plaintiff’s motion and denied the motion brought by insurer, Unum Life Insurance Company of America, ordering retroactive reinstatement of Jessica’s long-term disability (“LTD”) benefits pursuant to ERISA § 502(a)(1)(B).

Jessica L., a partner at an employment law firm, experienced a constellation of disabling symptoms beginning in 2020, including visual snow, head pressure, vertigo, and electric shock-like sensations culminating in her eventual cessation of work in 2021. Her condition proved diagnostically challenging. Although initial tests were inconclusive, subsequent evaluations identified a Rathke’s cleft cyst on her pituitary gland. Jessica underwent years of treatment with neurologists, endocrinologists, and a neurosurgeon, with multiple failed attempts to return to work even on a part-time basis. Despite these well-documented medical struggles, Unum terminated her long-term disability benefits twice; first in December 2022 (later reinstated), and again in May 2023. After exhausting her administrative remedies, Jessica filed suit under ERISA, seeking de novo review of Unum’s denial.

Consistent with a familiar pattern in ERISA disability litigation, Unum relied on the supposed absence of “clinical findings” to justify termination. It also relied on surveillance footage that showed Jessica driving, grocery shopping, and walking short distances, and its in-house consultants questioned the severity of her symptoms based on such daily activities and a selective reading of her records.

The court flatly rejected these rationales emphasizing that while the subjective nature of migraine and vestibular syndromes makes objective validation inherently difficult, it does not undermine their legitimacy as disabling conditions. The court cited multiple treating physicians, including UCSF specialists, who consistently diagnosed Jessica with chronic migraine, vestibular migraine, and visual snow syndrome, as well as hypopituitarism and growth hormone deficiency stemming from the pituitary lesion. The court highlighted that “none of Unum’s medical consultants specialized in pituitary disorders or headaches,” whereas plaintiff’s treating physicians were well-qualified specialists with longitudinal patient knowledge. The court credited the consistent, uncontradicted opinions of Dr. Ahmad (neurologist) and Dr. Blevins (pituitary specialist), who detailed how Jessica’s condition rendered her unable to meet the cognitive and executive demands of legal practice.

Additionally, the court reiterated that under a de novo standard of review, plaintiff need only demonstrate by a preponderance of the evidence that she was disabled at the time of benefit termination. The court noted that attempts to return to work—often used by insurers as “gotcha” moments—were found here to support credibility rather than undermine it. Jessica’s documented struggle to maintain even part-time duties, combined with the brief and partial effectiveness of aggressive interventions (including neurosurgery), supported a finding of persistent disability. While the court stated that it could have resolved the case on the administrative record alone, it also considered supplemental evidence submitted with the Rule 52 motion. This included additional surgery in late 2024 and updated records showing the recurrence of Jessica’s pituitary cyst. The court permitted this extra-record evidence, faulting Unum for refusing Jessica a reasonable extension to gather treating physician input over the holidays and noted that the supplemental materials only bolstered her claim – notably a 2025 letter from Dr. Blevins confirming the enduring and disabling impact of her condition.

The court ordered retroactive reinstatement of benefits through the date of judgment. It rejected Unum’s argument that remand was required, citing Ninth Circuit precedent that allows reinstatement where the insurer’s decision was plainly unsupported by the record. Judge Lin emphasized that Unum “will not get a second bite at the apple” when its denial was based on selective interpretation of medical data contrary to the overwhelming evidence.

This case provides a roadmap for how courts may evaluate complex disabling conditions, particularly those involving episodic neurological impairments, and reject insurer attempts to cherry-pick surveillance and minor inconsistencies in medical record. If Unum or your disability insurer has denied or otherwise limited your ERISA benefits claim, contact us for assistance.