District of Massachusetts Finds Unum’s Denial of LTD Benefits Arbitrary and Capricious

On September 11, 2025, the U.S. District Court for the District of Massachusetts issued a notable ERISA decision in Rogers v. Unum Life Insurance Company of America & Unum Group, No. 1:22-CV-11399-AK, 2025 WL 2625324 (D. Mass. Sept. 11, 2025). Judge Angel Kelley ruled that Unum acted arbitrarily and capriciously when it denied long-term disability (“LTD”) benefits to the plaintiff, Dr. Rogers, a Senior Scientist at MKS Instruments, despite consistent medical evidence and prior findings of disability under other programs. The Court not only reversed Unum’s decision but also entered judgment in Dr. Rogers’s favor, ordering payment of LTD benefits and leaving open the award of attorney’s fees.

Background

Dr. Rogers was covered under his employer’s group LTD policy with Unum. The policy defined disability as the inability, due to sickness or injury, to perform the material and substantial duties of one’s regular occupation, supported by medical evidence and physician care.

Beginning in early 2020, Dr. Rogers’s health deteriorated due to connective tissue disease, emphysema, chronic pain, and related symptoms. He stopped working in February 2020 and initially received short-term disability benefits. He later applied for LTD, asserting that fatigue, pain, and reduced stamina made it impossible to sustain the demands of his scientific role.

Unum denied the claim in December 2020, concluding that the medical evidence did not support functional restrictions preventing work. Dr. Rogers appealed, but Unum reaffirmed its denial after both internal reviews and an independent medical examination. Although he provided further evidence, Unum maintained its position, prompting Dr. Rogers to file suit under ERISA in July 2022.

The Court’s Initial Remand

In October 2024, Judge Kelley remanded the matter to Unum for further review. The Court found that Unum’s earlier denial failed to comply with its obligations under the Regulatory Settlement Agreement (RSA)—a nationwide settlement requiring Unum to give “significant weight” to treating physicians’ opinions and to explain, in detail, any decision to discount them.

The Court flagged several deficiencies, including:

• Summarizing but not engaging with treating physicians’ opinions.
• Over-reliance on the absence of objective findings while ignoring subjective but clinically significant symptoms such as pain and fatigue.
• Failing to reconcile treating physicians’ views with the actual demands of Dr. Rogers’s job.
• Refusing to meaningfully consider later medical evidence that shed light on his condition during the elimination period.

Unum was instructed to issue a new decision that addressed these shortcomings.

Unum’s Revised Letter and Continued Deficiencies

On January 7, 2025, Unum issued its Revised Determination Letter, again denying benefits. Dr. Rogers argued that the new letter suffered from the same flaws as the earlier one. The Court agreed.

Judge Kelley found that while the Revised Letter acknowledged the opinions of Dr. Rogers’s treating physicians—including specialists in rheumatology, orthopedics, psychiatry, and primary care—it continued to discount them without adequate explanation. Instead, Unum relied on the absence of certain objective test results and leaned heavily on the views of internal reviewers who never examined Dr. Rogers.

The Court emphasized that fatigue, pain, and reduced stamina are inherently subjective but medically significant symptoms, and Unum’s approach violated the RSA’s requirement of giving treating physicians’ opinions significant weight.

Inconsistent Disability Determinations

Another critical factor was Unum’s inconsistency. The company had previously approved Dr. Rogers’s short-term disability benefits multiple times based on the same medical records it later rejected for LTD purposes. In addition, both the Social Security Administration and Unum’s own FMLA division recognized him as disabled during the same timeframe.

While recognizing that different programs may apply different standards, the Court held that Unum’s failure to explain these conflicting outcomes undermined the reasonableness of its LTD denial.

Reliance on Flawed Internal Review

The Court also noted parallels to Mundrati v. Unum Life Ins. Co. of Am. (W.D. Pa. 2025), which criticized Unum physician Dr. Scott Norris’s “record-only” review for ignoring treating doctors’ opinions and selectively relying on favorable evidence. Judge Kelley found the same deficiencies here, reinforcing that Unum’s process was arbitrary and capricious.

Conclusion

The Court concluded that the totality of the record supported only one outcome: Dr. Rogers was disabled under the policy during the elimination period. With consistent medical opinions, multiple prior disability approvals, and no reasoned explanation from Unum, its denial could not stand.

Accordingly, the Court entered judgment for Dr. Rogers, ordered payment of LTD benefits, and invited briefing on attorney’s fees.

This decision underscores the judiciary’s growing scrutiny of Unum’s claim-handling practices and highlights the continuing importance of the RSA in requiring Unum to meaningfully engage with treating physicians’ evidence.