N.D. California Holds LINA Wrongfully Denied Long-Term Disability Benefits to Engineer Suffering Cognitive Impairment Following COVID-19 Vaccination

In Doe v. Life Insurance Company of North America, No. 24-CV-00859-NW, 2026 WL 125617 (N.D. Cal. Jan. 16, 2026), the Northern District of California ruled in favor of a mechanical engineer who challenged the denial and termination of long-term disability benefits under an ERISA-governed plan. The plaintiff worked in a highly technical engineering role involving advanced missile systems and alleged that she became disabled after suffering cognitive and neurological symptoms following COVID-19 vaccination.

Life Insurance Company of North America (“LINA”), which both insured and administered the plan, denied benefits on the grounds that the plaintiff was not physically disabled and that any psychiatric impairment ended in early 2023. Following a bench trial on the administrative record under Rule 52, the court granted judgment for the plaintiff.

Standard of Review

The parties agreed that the court should apply de novo review. As a result, the court independently evaluated the evidence without deferring to LINA’s benefit determination and weighed whether the plaintiff proved, by a preponderance of the evidence, that she was disabled under the plan.

Material Duties of the Plaintiff’s Occupation

A central dispute concerned the nature of the plaintiff’s job duties.

LINA repeatedly characterized the plaintiff’s occupation as “sedentary,” focusing on the lack of physical exertion required. The court rejected that framing, holding that the plaintiff’s role as a mechanical engineer—particularly in a fast-paced aerospace and missile-program environment—required sustained concentration, complex problem-solving, technical judgment, and cognitive stamina.

The court emphasized that disability determinations must focus on the actual material duties of the occupation, not simply whether the job involves physical labor. Because the plaintiff’s job was primarily cognitive, the relevant question was whether her cognitive impairments prevented her from performing those duties.

Credibility of Subjective Symptoms and Objective Evidence

LINA argued that the plaintiff failed to prove disability because she lacked objective medical evidence demonstrating physical impairment. The court rejected that argument, explaining that ERISA does not permit an insurer to require objective proof where the claimant’s condition does not readily lend itself to definitive testing.

The court found the plaintiff’s subjective complaints—including severe fatigue, brain fog, impaired concentration, and post-exertional malaise—to be consistent, credible, and supported by treating-provider observations, longitudinal medical records, and third-party accounts. The plan did not require objective medical evidence, and LINA could not impose that requirement after the fact.

Weight Given to Treating Physicians vs. Reviewing Consultants

The court gave significant weight to the opinions of the plaintiff’s treating physicians, all of whom personally examined her and consistently concluded that she lacked the cognitive stamina and processing ability required to perform her occupation.

In contrast, LINA relied heavily on consultants who conducted only paper reviews and discounted the plaintiff’s symptoms due to the absence of objective findings. The court found this approach unpersuasive, particularly where no provider who examined the plaintiff suggested malingering or symptom exaggeration.

The court also criticized LINA for selectively relying on portions of its own consultants’ opinions—crediting conclusions that the plaintiff could not sustain cognitively demanding work, while arbitrarily limiting disability to a brief period without a reasoned explanation.

Failure to Properly Evaluate Cognitive Impairment

The court identified a recurring flaw in LINA’s analysis: a failure to meaningfully assess the cognitive demands of the plaintiff’s occupation.

Although LINA initially insisted that a neuropsychological IME was necessary to resolve the appeal, it abandoned that evaluation mid-process and later faulted the plaintiff for lacking objective cognitive testing. The court held that LINA could not rely on an evidentiary gap created by its own decision not to complete the IME.

Disability Established Under the “Regular Occupation” Standard

After weighing the full record, the court concluded that the plaintiff met her burden of proving that she could not perform each and every material duty of her regular occupation. Her credible symptom reports, combined with consistent treating-provider observations, established disability even in the absence of objective test results.

The court therefore held that LINA wrongfully denied benefits under ERISA.

Remedy and Remand

The court ordered retroactive reinstatement of long-term disability benefits under the plan’s “regular occupation” definition from the date benefits were terminated through the end of the applicable period.

Because LINA never evaluated whether the plaintiff was disabled under the plan’s subsequent “any occupation” standard, the court remanded that issue to the administrator for determination in the first instance. Having granted full relief on the benefits claim, the court declined to address the plaintiff’s breach-of-fiduciary-duty claim.

Key Takeaways

• Courts will scrutinize the actual cognitive demands of professional occupations rather than relying on “sedentary” labels.
• Insurers may not require objective evidence when a condition does not reasonably permit it and the plan does not demand it.
• Treating-provider observations and longitudinal evidence may outweigh file-review opinions.
• Administrators cannot benefit from evidentiary gaps caused by their own failure to complete necessary evaluations.