Eleventh Circuit Affirms Termination of Long-Term Disability Benefits Where Claimant Failed to Provide Objective Medical Evidence of Continued Inability to Lift Fifty Pounds

In Dunham-Zemberi v. Lincoln Life Assurance Company of Boston, No. 22-13316, Not Reported in Fed. Rptr., 2026 WL 1031851 (11th Cir. Apr. 16, 2026), the Eleventh affirmed Lincoln Life Assurance Company of Boston’s denial of ERISA-governed long-term disability benefits. Plaintiff worked as a store manager for Mattress Firm, where one of his material and substantial duties was lifting up to fifty pounds. In November 2019, he suffered a spinal injury during a skiing accident and, following spinal fusion surgery, began receiving long-term disability benefits under his employer’s group plan administered by Lincoln. Lincoln subsequently terminated Bryce’s benefits, concluding that he had failed to provide proof of his continued disability as required by the plan. Bryce appealed administratively and then filed suit under ERISA § 502(a)(1)(B). The district court granted summary judgment in Lincoln’s favor, and the Eleventh Circuit affirmed.

Applying the Williams multi-step framework, the court first considered whether Lincoln’s decision was de novo wrong. The plan defined “proof” of disability to include standard diagnosis, chart notes, lab findings, test results, x-rays, and other forms of objective medical evidence, and provided that monthly benefits would cease upon the covered person’s failure to provide proof of continued disability. The court concluded that the objective medical evidence in the record demonstrated Bryce was capable of performing his occupational duties, not the contrary. Eight months post-surgery, his orthopedic surgeon found no complications from imaging, rated his strength and reflexes at five out of five in all extremities, and referred him to a pain psychologist who observed no pain behaviors. Two independent physician reviewers commissioned by Lincoln (both physiatrists) concluded that the records supported no specific restrictions or limitations and that Plaintiff had the strength and endurance to sustain full-time, unrestricted work activities.

The court rejected each of Plaintiff’s counterarguments. First, Plaintiff contended that Lincoln incorrectly required objective medical evidence to establish continued disability. The court disagreed, reading the plan’s proof requirements to unambiguously demand objective medical evidence and noting that an identical provision had been construed consistently in Doyle v. Liberty Life Assurance Co. of Boston, 542 F.3d 1352 (11th Cir. 2008). Second, Plaintiff argued that Lincoln bore an obligation to follow up with his treating providers before terminating benefits. The court rejected this theory as well, holding consistent with Melech v. Life Insurance Co. of North America, 739 F.3d 663 (11th Cir. 2014) that the plan placed the burden of proving continued disability on the claimant, and Lincoln was not required to ferret out evidence Bryce did not provide.

Third, Plaintiff argued that he had in fact submitted sufficient objective medical evidence, pointing to three items: a residual functional capacity evaluation by his physical therapist, a letter from his primary care physician, and an earlier medical review commissioned by Lincoln. The court found none of these sufficient. The capacity evaluation purported to measure his maximum lifting ability at fifteen pounds, but the heart rate monitoring that would have lent the test objective validity was taken only before lifting commenced, not during—leaving the reported limitation without objective support. The primary care physician’s letter suffered from the same deficiency, as it simply restated the capacity evaluation’s unsupported conclusions without independent clinical basis. And the earlier Lincoln-commissioned review predated December 2020 and could not speak to Plaintiff’s functional status as of January 2021, when benefits were terminated. Because the inquiry ended at the first step of the Williams framework, the court found that Lincoln’s decision was not de novo wrong and affirmed.