Eighth Circuit Affirms Award of Long-Term Disability Benefits Based on Determination that Plaintiff Was Disabled from Sedentary Work Due to her Physical Ailments

In Weyer v. Reliance Standard Life Ins. Co., No. 23-2862, __F.4th__, 2024 WL 3577374 (8th Cir. July 30, 2024), the Eighth Circuit considered Reliance Standard’s challenge of the district court’s award of long-term disability benefits to Plaintiff Weyer. The court affirmed the district court’s determination, finding that the district court did not clearly err in finding that Plaintiff was not capable of performing even sedentary work, satisfying the disability policy’s requirement of disability from “any occupation.” The court also determined that the district court did not clearly err in concluding that Plaintiff’s anxiety and depression were not “but-for causes” of her inability to work, such that Reliance Standard cannot limit Plaintiff’s claim to 24 months of benefits under the policy’s mental or nervous disorders clause.

Plaintiff filed a long-term disability (LTD) claim with Reliance Standard through her employer when her medical conditions of chronic fatigue syndrome/myalgic encephalomyelitis (ME/CFS), Lyme disease, migraine headaches, neurocognitive disorder, brain fog, and several other ailments, prevented her from continuing to work. Reliance paid her claim for 24 months under its policy’s definition of Totally Disabled, which requires, for the first 24 months, disability from one’s Regular Occupation. After 24 months, one must be disabled from “Any Occupation,” and Reliance Standard determined that Plaintiff did not meet this definition of disability because she can perform sedentary work. Reliance Standard also determined that Plaintiff’s anxiety and depression contributed to her disability and the maximum payment for disabilities caused by mental or nervous disorders is 24 months.

Plaintiff filed suit against Reliance Standard under ERISA Section 502(a)(1)(B). The district court, on de novo review, ruled in her favor. It found that nothing in the record suggested that Plaintiff’s mental health issues caused or contributed to her inability to work and that the evidence supported Plaintiff’s disability from even sedentary work. Reliance Standard appealed.

In affirming the decision of the district court, the Eighth Circuit noted that the standard of review is one for clear error. The district court cited ample evidence in the record showing that Plaintiff lacked sedentary-work capacity, including opinions of her treating physicians and Plaintiff’s favorable Social Security Disability Insurance determination. The district court discredited surveillance allegedly showing Plaintiff mowing the lawn, because even if the video was of the Plaintiff, it was consistent with her doctor’s opinion that Plaintiff could occasionally on a good day push a lawnmower over a small yard. Even though there was evidence suggesting that Plaintiff could work, it was not clear error for the district court to find that Plaintiff was disabled.

With respect to the limitation for mental or nervous disorders, the court noted that the policy provides that “Monthly Benefits for Total Disability caused by or contributed to by mental or nervous disorders will not be payable beyond an aggregate lifetime maximum duration of twenty-four (24) months.” The appropriate standard is “but-for” causation; that is, a claimant’s mental health disorders caused or contributed to her total disability if, but for the disorders, the claimant would not be disabled. This interpretation accords with the opinions of the court’s sister circuits addressing this “caused by or contributed to by” language. With this lens, the court found that the district court supported its conclusion that Plaintiff’s physical conditions independently rendered her unable to work. Finding no clear error, the court affirmed.