Eleventh Circuit Affirms Termination of Long-Term Disability Benefits Where Plan Vested Discretion and Insurer Relied on Multiple Medical and Vocational Reviews

In Dunn v. Life Insurance Company of North America, No. 25-12108, 2026 WL 2529506 (11th Cir. Aug. 27, 2026), the Eleventh Circuit affirmed the district court’s grant of judgment on the administrative record to Life Insurance Company of North America (LINA) in Plaintiff’s action challenging the termination of her long-term disability benefits. Plaintiff, formerly a customer service associate for Lowe’s, was injured in a car crash and, six years later, stopped working and applied for long-term disability benefits based on osteoarthritis in her right hip and pain in her legs and back that were exacerbated by hip surgery. LINA administered the policy as claims fiduciary and paid benefits as the insurer, and the policy granted LINA discretionary authority to decide questions of eligibility for coverage or benefits. To qualify for benefits, a claimant initially had to show she could no longer perform the duties of her regular occupation; to continue receiving benefits after twenty-four months, she had to satisfy the higher standard of proving she was unable to perform the material duties of any occupation for which she was or could reasonably become qualified.

LINA initially approved the claim, but after twenty-four months, when the definition of disability shifted from regular occupation to any occupation, LINA terminated benefits based on Plaintiff’s surgeon’s opinion that she could perform a sedentary job, an independent medical assessment by Dr. Kornfield reaching the same conclusion, and a vocational assessment identifying two alternative occupations available in her area, information clerk and gate guard. During the administrative appeal, LINA obtained a second vocational assessment and evaluations from three additional medical professionals, provided Plaintiff a preliminary decision and an opportunity to respond, and, after Plaintiff did not respond, upheld the termination. Plaintiff’s counsel later withdrew, and she proceeded pro se in the district court and on appeal.

Because the policy expressly vested LINA with discretion, the court reviewed the decision under the arbitrary-and-capricious standard, applying the Eleventh Circuit’s six-step framework from Blankenship v. Metropolitan Life Insurance Co. and electing to skip the first step. The court held that LINA reasonably relied on the findings of four medical professionals, the independent medical examination, and the two vocational assessments to conclude that Plaintiff could perform sedentary work and no longer met the policy’s definition of disabled. The court reasoned that as long as a reasonable basis appears for the decision, it must be upheld even if evidence would support a contrary conclusion. LINA’s dual role as claims fiduciary and payor was merely a factor in the analysis and did not render the decision unreasonable, particularly because LINA had taken active steps to reduce potential bias and promote accuracy.

The court rejected each of Plaintiff’s six arguments. It held that the medical evaluations supported her ability to perform the identified jobs, which did not require her to walk far or remain in a single position; that reliance on file reviews rather than live examinations was not arbitrary and capricious absent other troubling evidence; that her therapist’s contrary opinion was not in the administrative record; that the documentation errors she identified, such as describing her hip reconstruction as a replacement, were immaterial to the disability determination; that a Social Security disability finding is not coextensive with ERISA because the two schemes apply different standards; and that she was not denied her day in court because review was properly limited to the administrative record. The court affirmed.