Eleventh Circuit Upholds LINA’s Denial of Long-Term Disability Benefits Despite Social Security Award

In Walker v. Life Insurance Company of North America, No. 24-13066, 2025 WL 2327989 (11th Cir. Aug. 13, 2025), the Eleventh Circuit affirmed a district court ruling upholding Life Insurance Company of North America’s (“LINA”) denial of long-term disability (“LTD”) benefits to a former branch supervisor, despite the claimant’s award of Social Security Disability Insurance (“SSDI”) benefits. The court found no clear error in the district court’s determination that LINA’s medical and vocational evidence outweighed the claimant’s proof of disability under the Employment Retirement Income Security Act (“ERISA”).

Walker worked as a branch supervisor for D.R. Horton, earning over $286,000 annually, when she stopped working in 2018 due to knee, back, and shoulder pain. Under Horton’s group disability plan, administered by LINA, she received 24 months of LTD benefits after demonstrating she could not perform the material duties of her “Regular Occupation” or earn 80% of her indexed earnings in that role.

The policy shifted after two years: to continue benefits, Walker had to prove she could not perform the material duties of any occupation for which she was qualified by education, training, or experience, and could not earn 60% or more of her indexed earnings.

Several months before her initial benefits expired, LINA began reassessing her claim. Following an independent medical examination by an orthopedic surgeon, LINA’s vocational department concluded she could perform sedentary work, identifying “Manager, Financial Institution” as a suitable position. Based on this review, LINA terminated her benefits in November 2020.

Walker appealed, submitting a Functional Capacities Evaluation (“FCE”) performed by a physical therapist, which rated her abilities “Below Sedentary” and concluded she would often need extended reclined sitting periods due to pain. Her primary care physician concurred. LINA sent the FCE and updated records to two independent specialists: Dr. Donald Getz (orthopedic surgery) and Dr. Roger Belcourt (occupational medicine). Both found the FCE inconsistent with objective imaging results, placed no restrictions on sitting, and found limited restrictions on other activities. Dr. Getz also spoke with Walker’s primary care physician, who confirmed some standing/walking limits but did not endorse total work incapacity.

Walker also submitted a report from vocational expert Larry Underwood, who disputed LINA’s job-match analysis and argued that no occupations met the policy’s salary threshold given her restrictions. LINA’s vocational department stood by its initial analysis, and LINA ultimately upheld its decision to terminate benefits.

Walker sought judicial review, arguing her objective evidence—particularly the FCE, MRIs, and X-rays—proved she was disabled, that LINA’s consulting physicians’ opinions were insufficient to outweigh her evidence, that no qualifying jobs existed in the national economy meeting the policy’s salary requirements, and that her SSDI award was persuasive evidence of disability.

The district court, applying Rule 52 findings of fact and conclusions of law, found LINA’s denial was correct and entered judgment in the insurer’s favor. (In a footnote, the court addressed and dismissed Walker’s argument that the district court erred by not applying the summary judgment standard since Walker did not raise this argument in her initial brief on appeal and did not make this argument in the district court.)

On appeal, the Eleventh Circuit reviewed legal questions de novo and factual findings for clear error.

1. Disability Determination

The court held it was not clear error for the district court to discount the FCE. LINA’s consulting physicians provided reasoned explanations for finding the FCE inconsistent with objective imaging and clinical findings. While recognizing Walker’s orthopedic issues, all three consulting physicians (including the IME doctor) concluded she could sit without restriction and perform sedentary work with some activity limits. The court found the district court reasonably credited these opinions over the FCE and Walker’s own doctors.

2. Jobs in the National Economy

Walker argued that “Manager, Financial Institution” was not equivalent to her prior role and that her restrictions disqualified her from the job. The court noted that under the policy, “Regular Occupation” was determined by its description in the national economy, not her actual job tasks. Comparing the vocational evidence, the court found substantial overlap between her past position and the identified occupation. It also rejected her argument that restrictions on overhead reaching eliminated the position, finding she could use her non-dominant arm for such tasks.

3. Social Security Benefits

The court reiterated that an SSDI award is not dispositive under ERISA. Here, the SSA did not have the benefit of the consulting physicians’ evaluations or the expanded record. The district court’s decision to give the SSDI award little weight was therefore not erroneous.

The Eleventh Circuit concluded that the district court did not clearly err in finding LINA’s decision correct under the policy’s “any occupation” standard for disability. It held that substantial evidence supported LINA’s reliance on its medical consultants over the FCE, that vocational analysis properly identified comparable work within Walker’s capabilities and salary threshold, and that the Social Security award was not controlling. Finding no error in the district court’s reasoning, the appellate court affirmed the judgment in LINA’s favor, leaving Walker without further LTD benefits.