District Court Holds Insurer Did Not Abuse Discretion in Terminating LTD Benefits Based on Medical File Review, Activity Evidence, and Independent Physician Opinions

In Sramek v. United Of Omaha Life Insurance Company, et al., No. 1:25-CV-00576-MSN-LRV, 2026 WL 81903 (E.D. Va. Jan. 12, 2026), the Eastern District of Virginia upheld an insurer’s termination of long-term disability (“LTD”) benefits under an abuse-of-discretion standard, concluding that the administrator reasonably determined the claimant was no longer disabled within the meaning of the plan. The court emphasized that United of Omaha conducted a thorough review of the administrative record, reasonably credited independent medical opinions over conclusory treating-physician statements, and permissibly relied on activity evidence and vocational analysis to assess both the physical and cognitive demands of the claimant’s occupation as performed in the national economy. Viewing the record as a whole, the court held that the termination decision reflected a deliberate, principled reasoning process supported by substantial evidence and was not undermined by the insurer’s structural conflict of interest.

Procedural posture and standard of review

Plaintiff Sramek sued United of Omaha Life Insurance Company under ERISA § 502(a)(1)(B) after the insurer terminated his LTD benefits. The parties filed cross-motions for summary judgment. Because the LTD policy expressly granted United of Omaha discretionary authority to determine eligibility and construe plan terms, the court reviewed the termination decision under the abuse-of-discretion standard, which the Fourth Circuit has repeatedly described as “highly deferential.” The court’s role was limited to determining whether the decision resulted from a deliberate, principled reasoning process and was supported by substantial evidence.

In evaluating reasonableness, the court applied the familiar Booth factors, including the adequacy of the evidence, consistency with plan language, the reasoning process used, and any conflict of interest.

Relevant plan language

The policy defined “Disability” as being prevented from performing at least one of the material duties of the claimant’s regular occupation. “Regular occupation” was defined by reference to how the occupation is performed in the national economy, not the claimant’s specific employer. The policy also defined “material duties” as essential tasks that “cannot be reasonably omitted or modified,” and vested United of Omaha with full discretionary authority over benefit determinations.

United of Omaha’s decision-making process

The court first addressed whether United of Omaha employed a reasoned and principled process. It found that the insurer conducted a thorough review, which included:

• Medical records from the claimant’s treating physicians over multiple years,
• Written physician statements,
• A vocational analysis classifying the occupation as sedentary with frequent travel,
• Review of prescription medications,
• Surveillance and activity evidence,
• A nurse file review, and
• Independent reviews by two board-certified physicians retained through a third-party vendor.

The court rejected the plaintiff’s argument that United of Omaha was required to defer to treating physicians, emphasizing that ERISA does not incorporate a treating-physician rule under Black & Decker v. Nord. The court also rejected the contention that reliance on surveillance or activity evidence was improper, noting Fourth Circuit precedent approving administrators’ use of such evidence to test claimed limitations.

Based on the breadth of the evidence reviewed and the use of multiple independent medical reviewers, the court concluded that the insurer’s process satisfied ERISA’s reasoned-decision requirement.

Physical capacity analysis

Turning to the merits, the court held that substantial evidence supported United of Omaha’s conclusion that Sramek could perform the physical demands of his occupation as defined by the policy.

United of Omaha initially paid benefits following Sramek’s lumbar surgery and continued them for nearly two years. In 2024, however, it determined that his condition had improved. The insurer relied on:

• Treating records documenting largely normal neurological exams and stable imaging,
• Notes indicating that pain was “stable” and under fair control,
• Evidence that Sramek could sit comfortably, ambulate normally, and engage in significant recreational activity,
• A nurse reviewer’s conclusion that the record did not support an inability to perform sedentary work, and
• An independent neurosurgeon’s opinion that there were no objective neurological deficits or definitive physical limitations precluding full-time work.

The court emphasized that the plaintiff bore the burden of showing the decision lacked support in the record and rejected the argument that United of Omaha was required to produce affirmative proof that Sramek could tolerate long meetings or travel. The court also found it reasonable for the insurer to weigh evidence of extensive golf and recreational travel—including multi-day trips and frequent rounds of golf—against assertions that sitting and travel were intolerable.

Although one reviewing physician initially suggested sitting limitations, the court concluded that such limitations did not render the decision unreasonable given the plan’s definition of “material duties” and the administrator’s discretion to conclude that reasonable positional accommodations would allow performance of essential tasks.

Cognitive capacity analysis

The court likewise found substantial evidence supporting United of Omaha’s determination that Sramek could perform the cognitive demands of his occupation despite chronic pain and opioid use.

Medical records showed that Sramek had been taking opioids for years, including while working, and consistently documented minimal side effects, normal mental status examinations, and no observed cognitive impairment. The independent physician concluded that there was no evidence supporting cognitive restrictions attributable to pain or medication. While Sramek’s treating surgeon opined that pain and narcotics affected mentation, the court characterized those opinions as largely conclusory and unsupported by objective findings. Under Nord, the administrator was entitled to credit the independent reviewer over the treating physician.

Conflict of interest

Finally, the court addressed United of Omaha’s structural conflict as both claim evaluator and payor. Applying MetLife v. Glenn and Fourth Circuit precedent, the court treated the conflict as one factor among many. It found no evidence that the conflict influenced the decision, noting that United of Omaha initially approved benefits, paid them for nearly two years, and relied on independent medical reviewers whose compensation was not outcome-dependent. These factors weighed against giving the conflict significant weight in the abuse-of-discretion analysis.

Holding

Considering the Booth factors collectively, the court held that United of Omaha’s termination decision was the product of a deliberate, principled reasoning process and was supported by substantial evidence. It granted summary judgment to United of Omaha and upheld the termination of LTD benefits.