Ninth Circuit Affirms Denial of ERISA Disability Benefits, Upholding District Court’s Conflicting-Evidence Finding in Unum Long-Term Disability Dispute

In Jump v. Unum Life Insurance Company of America, No. 25-1021, 2026 WL 1847149 (9th Cir. June 26, 2026), the Ninth Circuit affirmed the denial of long-term disability benefits under an ERISA-governed plan administered by Unum Life Insurance Company of America, leaving in place a Central District of California order that found Plaintiff had not carried her burden of proving she was disabled under the plan’s terms. The appellate panel decided two narrow procedural questions and declined to recount the underlying facts. The merits reasoning belongs to the district court order issued below by District Judge Sunshine S. Sykes.

What did the Ninth Circuit decide on appeal?

The Ninth Circuit reviewed the district court’s denial of benefits for abuse of discretion, the standard that applies when an ERISA plan grants the administrator discretionary authority, and reverses only when the reviewed decision lies beyond the pale of reasonable justification under the circumstances. The panel held that the district court did not abuse its discretion when it declined to explain why its conclusion differed from that of the Social Security Administration, which had awarded Plaintiff benefits. The district court had taken judicial notice, at Plaintiff’s request, of the fact that the SSA awarded benefits, but it did not address the reasoning behind the SSA’s decision. The panel held that no such explanation was required, and it observed that the district court could not have explained any divergence from the SSA’s reasoning in any event because Plaintiff never submitted the SSA’s award notice to the district court.

The panel also held that the district court did not abuse its discretion when it declined to remand the matter to the plan administrator. The SSA award notice was issued after Unum rendered its final decision, so Unum could not be faulted for failing to consider it. The court distinguished Salomaa v. Honda Long Term Disability Plan, 642 F.3d 666, 679 (9th Cir. 2011), in which a plan administrator’s failure to consider an SSA award issued before the administrator’s final decision constituted an abuse of discretion. The court granted Plaintiff’s motion for judicial notice of the SSA award notice but noted that the notice confirmed the district court could not have examined the SSA’s reasoning even with access to the document. The panel affirmed.

This disposition is an unpublished memorandum and is not precedent except as provided by Ninth Circuit Rule 36-3.

What was the ERISA disability claim before the district court?

Plaintiff worked as a senior underwriter for fourteen years and was covered as a participant in Unum’s long-term disability plan through her employment. The plan, funded by a group insurance policy governed by ERISA, defined a participant as disabled when limited from performing the material and substantial duties of her regular occupation due to sickness or injury, with a corresponding loss in indexed monthly earnings. Plaintiff stopped working in March 2021 and claimed disability based on traumatic brain injury, post-concussion syndrome, spinal nerve damage, long-haul COVID symptoms, and related conditions, which she traced largely to a motor vehicle accident in which she was struck from behind. Unum denied her claim, finding no support beyond September 8, 2021, for restrictions that would have prevented her from performing her occupational duties, and Unum upheld the denial on administrative appeal.

How did the district court review Unum’s denial?

Judge Sykes reviewed the matter de novo on cross-motions for judgment under Federal Rule of Civil Procedure 52, treating the motions as a bench trial on the record. Under de novo review, the court evaluated whether Plaintiff had adequately established that she was disabled under the terms of the plan, with Plaintiff bearing the burden of proving by a preponderance of the evidence that she was disabled during the elimination period. The court granted Plaintiff’s request for judicial notice of the SSA award notice itself, recognizing that new evidence may be considered where a claimant could not have presented it during the administrative process, but the award notice had been issued after Unum closed the administrative record.

Why did the district court find Plaintiff had not met her burden?

The court concluded that the record was conflicting with regard to Plaintiff’s symptoms and her medical providers’ objective findings, and that Plaintiff therefore had not shown it was more likely than not that she was disabled. The court worked through the claimed bases for disability in turn.

On Plaintiff’s vision, the court credited the conclusions of Plaintiff’s treating optometrist regarding her eye-tracking difficulties but found the record conflicting. A July 2021 report reflected 20/20 vision and normal visual field results, another physician found no double vision and full visual fields on examination, and Plaintiff did not report vision difficulties to several other providers who specifically examined or asked about her eyes. The court also noted Plaintiff’s delay in starting recommended vision therapy and a documented statement suggesting possible low motivation during evaluations, and it concluded that the diagnoses resting on her vision deficiencies could not be accorded full weight.

On COVID, the court found that Plaintiff was not disabled solely due to long-haul symptoms, though those symptoms could have exacerbated her other conditions, and it stated it would consider the long-haul COVID in combination with her other cognitive complaints.

On the remaining cognitive deficiencies, the court addressed the diagnoses of the treating providers who concluded Plaintiff could not work. It found that the treating physician’s primary diagnosis rested mainly on subjective complaints and on monitoring treatment by other providers, and it noted that this physician had at one point signed a form agreeing with Unum’s reviewers that Plaintiff was not precluded from sedentary work before issuing a contradictory letter. As to the three pivotal diagnoses from Plaintiff’s neuropsychologist, neurologist, and an examining physician, the court found the record did not sufficiently corroborate the conclusions of disability. Mental status examinations across multiple providers documented normal attention span, concentration, and memory, MRI scans of the brain were interpreted as overall normal appearing, and the court found a number of inconsistencies throughout the administrative record pertaining to Plaintiff’s symptoms, including her representations about losing consciousness in the accident, which the court viewed with some skepticism given that emergency personnel arrived at the scene within seconds and the collision report made no mention of a loss of consciousness.

The court gave the opinions of Unum’s file-reviewing consultants less weight than those of Plaintiff’s treating physicians because the consultants never conducted an in-person examination, but it found their opinions helpful in identifying inconsistencies in the administrative record. The court granted Unum’s motion for judgment and denied Plaintiff’s, concluding that Plaintiff had not met her burden by a preponderance of the evidence. The Ninth Circuit’s memorandum disposition affirmed that result.