District Court Rules for Former Employee in ERISA Disability Dispute Finding That Unum Wrongly Denied Long-Term Disability Benefits for Mental Health Impairments

In Schwartz v. Unum Life Insurance Company of America, No. 24-cv-02444-TSH, 2025 WL 1827904 (N.D. Cal. July 1, 2025), on cross-motions for judgment pursuant to FRCP Rule 52, California Northern District Judge Thomas S. Hixson granted judgment in favor of plaintiff M. Schwartz, concluding that Unum improperly denied her long-term disability (LTD) benefits under an ERISA-governed policy. The court found that Schwartz proved by a preponderance of the evidence that she was disabled during the “Usual Occupation” period, rejecting Unum’s reliance on file-reviewing physicians and emphasizing the credibility and duration of Schwartz’s treating providers.

Schwartz, a seasoned marketing professional, worked as an Experience Marketing Operations Manager at Workday. Her role demanded flexibility, multitasking, and strong communication, traits she found increasingly difficult to sustain as her mental health deteriorated. Her symptoms stemming from major depressive disorder, anxiety, and atypical autism worsened amid the COVID-19 pandemic and work-related stressors.

She initially took short-term disability leave in August 2020, returned part-time in January 2021, and ultimately ceased working in March 2021. Despite attempts to secure a less demanding internal position, including taking a technical writing exam, Schwartz was terminated in November 2021. She filed for LTD benefits in February 2023, asserting continuous disability since October 31, 2021.

The group policy issued by Unum, and governed by ERISA, included a 180-day elimination period and a two-tiered definition of disability. At issue was whether Schwartz was continuously disabled from her “Usual Occupation” from October 31, 2021 to April 30, 2022. Unum concluded she was not, citing allegedly “normal” mental status examinations and her involvement in a nonprofit, Mothership HackerMoms.

The court emphasized the weight of evidence from Schwartz’s long-term treating psychiatrist, Dr. Lucas Van Dyke, and therapist, LCSW Chantal Rohlfing, both of whom consistently documented functional impairments, emotional instability, and failed return-to-work attempts. Dr. Van Dyke opined that any form of work caused distress and impairment, and LCSW Rohlfing explicitly rejected Unum’s insinuation that Schwartz was malingering. By contrast, the court gave minimal weight to Unum’s in-house consultants, none of whom examined Schwartz. Notably, the court discredited Unum’s reliance on mental status examinations documenting that she was “alert” or “oriented,” pointing out that such findings are not inconsistent with debilitating psychiatric conditions. The court cited precedent holding that high-functioning individuals can nonetheless suffer from disabling mental illness.

While Unum pointed to Schwartz’s volunteer work at Mothership HackerMoms as evidence of functional ability, the court found this comparison flawed. Schwartz credibly testified that such duties were limited, low-stakes, and required days of recovery, activity which was starkly different from her fast-paced, deadline-driven role at Workday. The court noted that the policy did not contain an “objective evidence” requirement and held that the neuropsychological evaluations, though imperfect, corroborated the treating providers’ findings.

Unum’s argument that Schwartz’s condition was “situational” and not disabling was roundly rejected. The court emphasized that her symptoms persisted both during and after her employment and had worsened upon attempts to return to work. Unum’s failure to exercise its contractual right to conduct an in-person examination also undermined the credibility of its denial.

Concluding that Schwartz had met her burden under the de novo standard of review, the court ordered Unum to pay benefits for the two-year maximum period applicable to mental health conditions. It also found Schwartz eligible to seek attorney’s fees under ERISA § 502(g).

If Unum or your disability insurer has denied or otherwise limited your ERISA benefits claim, contact us for assistance.