District Court Hands Win to Physical Medicine and Rehab Doctor Who Sued Unum for Denied Long-Term Disability Benefits

The case of Mundrati v. Unum Life Ins. Co. of Am., No. CV 23-1860, 2025 WL 896594 (W.D. Pa. Mar. 24, 2025) serves as a significant illustration of how disability claims are evaluated under the Employee Retirement Income Security Act (ERISA). The decision rendered by the United States District Court for the Western District of Pennsylvania on March 24, 2025, reveals the dynamic of long-term disability (LTD) claims and the responsibilities of insurance companies.

Dr. Mundrati filed a claim for long-term disability benefits after suffering from a traumatic brain injury (TBI) resulting from a motor vehicle accident in February 2018. Following her injury, Dr. Mundrati underwent a series of medical evaluations and treatments and returned to work under specific restrictions. In January 2021, her medical group terminated her employment due to her inability to meet the occupational requirements, which led her to file an LTD claim with Unum.

Dr. Mundrati’s claim pertained to Unum’s denial of her LTD benefits, which she argued was arbitrary and capricious. The court’s opinion addressed Unum’s classification of her job as a “physician,” a designation associated with light-duty work, as opposed to the more accurate classification of an “Interventional Spine Physician,” a medium-duty position.

Key Issues in the Case

1. Misclassification of Occupation: Unum classified Dr. Mundrati’s regular occupation as a physician rather than recognizing her specific role as an Interventional Spine Physician. This distinction is crucial because it directly impacts the definition of disability under the policy. Dr. Mundrati argued that her actual job duties required significant physical demands that were overlooked.
2. Evidence of Disability: The court scrutinized Unum’s assessment of Dr. Mundrati’s ongoing health issues, particularly its reliance on the opinions of external reviewers over that of her treating physicians. Unum’s denial was heavily based on a review of medical records, which the court found to be selective and lacking the necessary depth to accurately reflect Dr. Mundrati’s condition.
3. Time Relevance of Evidence: Unum denied the relevance of certain medical evaluations conducted after the elimination period, arguing they did not pertain to Dr. Mundrati’s condition during the period in question. The court found that this rationale was unfounded, as there were no substantial changes to her condition that would justify disregarding later evaluations.

Legal Framework under ERISA

Under ERISA, the review of disability claims rests on the terms of the insurance policy and the discretion afforded to the plan administrator. The court highlighted that Unum’s decision must be based on substantial evidence and a reasonable explanation. The arbitrary and capricious standard was applied that led to the ruling that Unum’s denial of benefits lacked the necessary justification.

Court Ruling

The court ultimately sided with Dr. Mundrati, granting her motion for summary judgment and denying Unum’s motion. The ruling emphasized that Unum’s decision was arbitrary due to its mischaracterization of her occupation, unjustified dismissal of relevant medical evidence, and reliance on a paper review instead of engaging with the claimant’s treating physicians.

Implications of the Decision

This case underscores the importance of accurate job classification and the necessity for insurance companies to provide thorough and reasoned evaluations when handling disability claims. It serves as a reminder for both claimants and insurers about the critical role of comprehensive medical assessments and the need for transparency in the decision-making process.

For professionals navigating the intricacies of ERISA and disability claims, Mundrati v. Unum illustrates the components between insurer discretion and the rights of claimants to receive fair evaluations based on the full evaluation of their medical conditions and job requirements.

Conclusion

The ruling in Mundrati v. Unum not only highlights the complexities surrounding disability insurance claims under ERISA but also exemplifies the judiciary’s role in ensuring that claimants are treated equitably. Understanding these pivotal cases will be essential for both legal professionals and individuals seeking to secure the benefits they deserve.