District Court Upholds Unum’s Denial of LTD Benefits Highlighting Evidentiary Requirements in Subjective Symptom ERISA Claims

In Stickley v. Unum Life Insurance Company of America, No. 3:24-CV-05364-TMC, 2025 WL 1094346 (W.D. Wash. Apr. 10, 2025), Washington Western District Judge Tiffany M. Cartwright granted Unum’s motion for judgment and denied Plaintiff’s cross-motion for judgment and motion to supplement the administrative record, finding that Plaintiff failed to demonstrate entitlement to long-term disability (“LTD”) benefits in this ERISA disability action.

Plaintiff Stickley, formerly a Chief Human Resources Officer, claimed long-term disability benefits from Unum Life Insurance Company under her employer’s disability plan. Stickley alleged that due to extreme fatigue, fever, brain fog, and body aches, she was unable to perform her job duties effectively, leading to her cessation of work in April 2019. Although Stickley’s symptoms began while employed, contemporaneous medical records lacked a definitive diagnosis or evidence of diminished work capacity. Stickley was later diagnosed with Chronic Fatigue Syndrome (CFS), fibromyalgia, and Epstein-Barr Virus (EBV) between 2022 and 2023.

Upon applying retroactively for disability benefits, Unum classified her claim as one for short-term disability (STD) benefits and denied it as untimely. Stickley then explicitly requested that Unum initiate a claim for LTD benefits, but Unum continued to deny her request by focusing solely on STD benefits, asserting that her medical records did not substantiate her inability to perform her job duties as of April 2019.

Stickley initiated legal proceedings against Unum, challenging the denial of LTD benefits, and filed a FRCP Rule 52 motion for judgment. Concurrently, Plaintiff also sought to supplement the administrative record with excerpts from Unum’s claims manual. Unum cross-moved for judgment on the administrative record, contending that Stickley failed to establish entitlement to benefits under the plan’s terms.

In deciding the cross-motions, the court first addressed whether Stickley adequately exhausted her administrative remedies before filing suit. ERISA mandates exhaustion of a plan’s internal review procedures prior to litigation. The court found that Stickley’s communications constituted a valid initial claim and subsequent appeal for LTD benefits. Despite Unum’s classification of her claim as solely involving STD benefits, Stickley had consistently communicated her intent to pursue LTD benefits, satisfying the exhaustion requirement.

The court proceeded to conduct a de novo review of Unum’s claims decision, whereby the court independently evaluated the evidence without deference to the plan administrator’s decision. Under a de novo review, the burden of proof lies with the claimant to demonstrate disability within the plan’s terms by a preponderance of the evidence. The court noted that conditions such as CFS and fibromyalgia, which are largely self-reported and difficult to diagnose objectively, necessitate corroboration by other evidence of functional limitations. The court found Stickley’s evidence insufficient to establish total disability as of April 2019. The October 2018 medical examination and subsequent reports lacked support for the severity of symptoms alleged. Additionally, non-medical evidence, such as performance issues cited by Stickley’s employer, did not conclusively link her job performance decline to her medical condition. The court also determined that retrospective medical evaluations and the SSDI determination did not convincingly relate back to the alleged onset of disability. Moreover, the court denied Stickley’s request to introduce Unum’s claims manual into the record. The court held that exceptional circumstances justifying the inclusion of extrinsic evidence were not present, as Unum’s procedural handling of the claim was irrelevant under de novo review.

Ultimately, the court concluded that Stickley failed to meet her burden of proof, granting judgment in favor of Unum while denying Stickley’s motions. This decision underscores the stringent evidentiary requirements for proving disability under ERISA plans, particularly for conditions with subjective symptoms like CFS and fibromyalgia.

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