Eleventh Circuit Upholds Unum’s Termination of Long-Term Disability Benefits Under Arbitrary-and-Capricious Review

In Eggleston v. Unum Life Insurance Company of America, No. 24-13678, 2025 WL 3472834 (11th Cir. Dec. 3, 2025), the Eleventh Circuit affirmed Unum’s decision to terminate a claimant’s long-term disability benefits, holding that substantial evidence supported the insurer’s determination that the claimant was no longer disabled under the policy’s “any gainful occupation” standard.

Plaintiff Eggleston, a clinical research nurse, stopped working in 2011 due to chronic pain stemming from multiple diagnosed conditions. Unum initially awarded long-term disability benefits for the “own occupation” period and later extended benefits under the “any occupation” definition based on findings that her symptoms—particularly her ability to sit or stand for only minutes at a time—prevented sustained work.

Over the next decade, Unum conducted periodic reviews, noting fluctuating but gradually improving clinical findings. Although Eggleston consistently reported significant pain, objective testing (imaging, inflammatory markers, and bloodwork) often remained normal or unremarkable.

In 2021, Unum obtained social media evidence showing Eggleston traveling, catering food events, attending long performances, and participating in activities allegedly inconsistent with her reported limitations. Unum then pursued additional reviews, including updated medical evaluations and independent physician assessments. Those experts concluded that her chronic conditions were stable, controlled with medication, and did not preclude sedentary work. A vocational expert identified several gainful occupations—triage nurse, utilization review coordinator, medical claims reviewer—that Eggleston could perform.

Unum terminated benefits; Eggleston appealed internally and then filed suit under ERISA § 502(a)(1)(B). The district court upheld Unum’s decision, finding that the record showed improved functional capacity, conflicting medical opinions, and a reasonable basis for crediting Unum’s experts over Eggleston’s treating providers, whose opinions were based heavily on self-reported pain. The court also relied on Eggleston’s publicly posted activities as supporting evidence of improved function.

Applying the Eleventh Circuit’s six-step Blankenship framework, the court assumed—without deciding—that Unum’s decision was “de novo wrong.” The analysis therefore proceeded to whether Unum had discretionary authority (yes) and whether the decision was supported by “reasonable grounds” (yes). Under the deferential arbitrary-and-capricious standard, the court emphasized:

• Competing medical opinions do not make the administrator’s decision arbitrary.

Plan administrators may assign different weights to conflicting medical evidence and are not required to defer to treating physicians. Unum’s independent experts reasonably concluded that Eggleston’s complaints were inconsistent with objective findings and functional observations.

• Social media and daily activities supported Unum’s conclusions.

Eggleston’s travel, catering, and event attendance suggested functional capabilities beyond those she reported to Unum and to her providers.

• Substantial evidence supported the determination that she could perform sedentary work.

The vocational analysis identified multiple suitable occupations; no objective medical evidence showed a total inability to work.

Because the court found reasonable grounds supported the determination, it affirmed without needing to weigh Unum’s structural conflict of interest. The Eleventh Circuit affirmed Unum’s termination of benefits, concluding that the insurer’s decision was supported by substantial evidence and was neither arbitrary nor capricious.