In Guy v. Reliance Standard Life Insurance Co., No. 2:24-CV-00293-JCG, 2026 WL 539534 (D. Ariz. Feb. 20, 2026), the U.S. District Court for the District of Arizona reversed Reliance’s denial of long-term disability (LTD) benefits to an ICU nurse suffering from chronic fatigue syndrome and multiple autoimmune and endocrine disorders. Applying Ninth Circuit precedent, the court concluded that Reliance’s decision was illogical, implausible, and unsupported by the record when viewed cumulatively.
Standard of Review and Structural Conflict
Because the policy granted Reliance discretionary authority, the court reviewed the denial for abuse of discretion under Firestone Tire & Rubber Co. v. Bruch. However, as required by Metropolitan Life Insurance Co. v. Glenn and Abatie v. Alta Health & Life Insurance Co., the court weighed Reliance’s structural conflict of interest as a factor in that analysis, since Reliance both determined eligibility and paid benefits.
The court emphasized that abuse-of-discretion review is not a rubber stamp. Under Ninth Circuit law, a decision must be upheld only if it is reasonable—not illogical, implausible, or unsupported by inferences that may be drawn from the record.
Objective Evidence and Chronic Fatigue: The Salomaa Rule
A central issue was Reliance’s insistence on objective evidence to substantiate the claimant’s chronic fatigue and cognitive dysfunction.
Relying heavily on Salomaa v. Honda Long Term Disability Plan, the court reiterated that it is arbitrary and capricious to require objective proof for conditions that do not lend themselves to objective testing. In Salomaa, the Ninth Circuit held that chronic fatigue syndrome cannot be discounted simply because there is no laboratory test confirming it.
Here, Reliance acknowledged the claimant’s ongoing reports of fatigue, brain fog, and related symptoms, but denied benefits because testing and physical examinations were “unremarkable.” The court found that this reasoning effectively conditioned benefits on proof that cannot exist. Under Salomaa, that approach is unreasonable.
The court also noted that many medical conditions depend significantly on patient-reported symptoms. ERISA does not permit an insurer to dismiss such evidence merely because it lacks laboratory confirmation.
Selective Review and the Requirement of a “Full and Fair Review”
The court next addressed Reliance’s treatment of the medical record. Although the administrative record contained documentation of ongoing fatigue, autoimmune symptoms, specialist evaluations, and continued treatment after the onset date, Reliance concluded there were no physical restrictions preventing work.
Citing Black & Decker Disability Plan v. Nord, the court recognized that administrators are not required to give special deference to treating physicians. However, they may not arbitrarily refuse to credit reliable evidence.
Under ERISA’s “full and fair review” requirement and Ninth Circuit precedent, an administrator must meaningfully consider the record as a whole. The court found that Reliance’s conclusion required disregarding significant portions of the evidence and drawing inferences inconsistent with the documented course of treatment.
This selective analysis—especially in the presence of a structural conflict—supported heightened skepticism.
Paper Reviews and the Failure to Obtain an Independent Examination
The court also examined Reliance’s reliance on paper reviews. Although ERISA does not mandate an in-person independent medical examination in every case, Ninth Circuit decisions such as Montour v. Hartford Life & Accident Insurance Co. and Salomaa recognize that exclusive reliance on file reviews may be a factor in determining whether a denial was reasonable—particularly where credibility and subjective symptoms are central.
The policy permitted Reliance to require a physical examination. Yet Reliance declined to do so while simultaneously criticizing the lack of objective evidence. The court observed that insurers may avoid examinations because of the risk that an examining physician could confirm disability. In this case, the decision to rely solely on paper reviews contributed to the court’s skepticism regarding the thoroughness and accuracy of the determination.
Mischaracterization of the Claimant’s Occupation
One peer reviewer described the claimant’s job as sedentary administrative work that did not involve lifting or patient care. In fact, she was an ICU nurse whose position required standing, walking, lifting up to 50 pounds, and direct patient treatment.
Because the policy’s definition of disability during the initial period focused on the ability to perform the material duties of the claimant’s regular occupation, an accurate understanding of those duties was essential.
The court rejected Reliance’s argument that the mischaracterization was immaterial. Under Ninth Circuit precedent, a benefits determination must be grounded in the actual occupational demands at issue. Reliance’s reliance on an incorrect description of the job further undermined the reasonableness of its decision.
The Social Security Disability Award
The claimant also submitted a favorable Social Security Administration (SSA) disability decision. While SSA determinations are not binding on ERISA plan administrators, the Ninth Circuit has made clear—again in Salomaa—that such decisions are significant evidence. Failure to meaningfully address them may support a finding of abuse of discretion.
The court concluded that Reliance gave the SSA award minimal and unpersuasive consideration, particularly given the flaws in its own peer review process.
Cumulative Effect of Multiple Conditions
Finally, the court found that Reliance failed to evaluate the cumulative impact of the claimant’s conditions.
Ninth Circuit district courts have repeatedly held that administrators must consider the combined effect of multiple impairments rather than analyzing each diagnosis in isolation. Here, Reliance separated “mental” from “physical” impairments and concluded that only the mental conditions were disabling (subject to the policy’s 12-month limitation).
The court determined that this piecemeal approach failed to account for how chronic fatigue, autoimmune disorders, endocrine dysfunction, cognitive impairment, and depression interacted. When the record was viewed as a whole, the denial lacked reasonable support.
The Result
After weighing the structural conflict, the procedural irregularities, the improper demand for objective proof, the flawed occupational analysis, the inadequate consideration of the SSA award, and the failure to assess cumulative impairment, the court concluded that Reliance abused its discretion.
The court reversed the denial, remanded with instructions to award benefits, and held that the claimant was entitled to seek attorneys’ fees and costs under ERISA.
Key Principles Reinforced by the Decision
The ruling reinforces several established Ninth Circuit principles:
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An insurer cannot require objective proof of a condition that inherently lacks objective testing.
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ERISA requires a full and fair review of the entire administrative record.
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Abuse-of-discretion review remains meaningful, particularly where a structural conflict exists.
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Occupational analysis must accurately reflect the claimant’s actual job duties.
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Social Security disability findings are significant evidence that must be addressed.
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Disability determinations must consider the cumulative effect of all impairments.
In sum, the court concluded that Reliance’s denial was not merely debatable—it was unreasonable under governing ERISA standards.
