Ohio Federal Court Revives ERISA Disability Claim After Lincoln National Relies Only on Paper Reviews

In Oliver-Smith v. Lincoln National Life Insurance Company, No. 1:23-cv-276, 2026 WL 2905291 (S.D. Ohio Sept. 28, 2026), United States District Judge Jeffery P. Hopkins found that Lincoln’s termination of a long-term disability claimant’s ERISA benefits was arbitrary and capricious, vacated the decision, and remanded the claim for a renewed full and fair review. The case is a useful illustration of how a claimant can prevail even under the deferential standard of review, and of the risk an insurer runs when it rejects a psychiatric disability claim on a paper record alone.

What was the ERISA disability claim about?

Plaintiff worked for nearly three decades at Duke Energy as a Gas Systems Operator Mechanic II, a safety-sensitive role that involved operating, maintaining, and repairing natural gas distribution equipment, responding to emergencies, and regulating gas pressure, work in which a lapse in attention could risk serious injury or death. She stopped working in February 2021 and claimed disability based on panic disorder, major depressive disorder, and generalized anxiety disorder. Lincoln administered the Duke Energy long-term disability plan and paid short-term disability benefits, then approved long-term disability benefits under the plan’s “Own Occupation” standard effective August 10, 2021. After a continuing-eligibility review, Lincoln terminated those benefits effective February 15, 2022, and upheld that decision on administrative appeal in a final determination dated January 5, 2023. Plaintiff then sued under 29 U.S.C. § 1132(a)(1)(B).

Why did the court apply the arbitrary and capricious standard instead of de novo review?

Plaintiff pressed several arguments for de novo review, and the court rejected each. First, she argued that discretionary authority ran only to “Liberty,” the original insurer named in the policy, not to Lincoln. The court held that Lincoln succeeded to Liberty’s discretionary authority through a series of acquisitions and mergers and called the contrary argument meritless. Second, she argued that Lincoln’s reliance on paid file reviewers, without any independent plan interpretation, required de novo review under Thompson v. J.C. Penney Co. The court distinguished Thompson, explaining that the administrator there never gave the claimant a plan interpretation or an explanation for the denial, so there was nothing to defer to. Here, Lincoln identified the governing eligibility requirements, applied them, and explained its decision. Third, she argued that claims-procedure violations stripped the decision of deference under 29 C.F.R. § 2560.503-1(l). The court found no procedural violation, concluding that Lincoln gave timely notice and specific reasons at every level and considered the materials Plaintiff submitted on appeal.

Did a medical report belonging to another patient doom the denial?

No. Plaintiff argued that the termination was arbitrary and capricious because an early peer reviewer referenced an April 21, 2021 progress report that, as the record later revealed, belonged to a different patient and described someone whose condition had improved and who was ready to return to work. The court agreed the report was erroneous but found no proof that it materially affected the outcome. Lincoln’s final decision rested largely on the appeal-level review by Dr. Barbara Center, a board-certified psychiatrist, and nothing showed that Dr. Center relied on the mistaken report. The court therefore rejected this argument.

Why was Lincoln’s reliance on file reviews alone arbitrary and capricious?

This is where Plaintiff prevailed. The court explained that nothing requires a plan administrator to obtain an in-person examination before denying benefits, and that reliance on a file review is not inherently improper. But the absence of an in-person examination is a relevant consideration where the claimed impairment is psychological, because a paper review can be an inadequate basis for assessing the severity and functional effects of mental-health symptoms. Plaintiff’s treating providers, including her primary care physician and her therapists, consistently described panic attacks, anxiety, depression, insomnia, and difficulty focusing, and several opined that she could not return to work. The central question was whether those symptoms and her medications materially impaired her ability to safely perform a hazardous, safety-sensitive occupation. The plan expressly authorized an in-person psychiatric examination, yet Lincoln relied exclusively on non-examining reviewers and discounted the providers who had actually observed Plaintiff. On that record, the court held, sole reliance on file reviews was inadequate.

How did the Social Security award factor into the decision?

It reinforced the court’s conclusion. Lincoln required Plaintiff to apply for Social Security disability benefits and benefited from the resulting offset, and the Social Security Administration found her disabled with an onset date of February 2, 2021. The court acknowledged that Social Security applies different standards, but faulted Lincoln for failing to meaningfully explain why the agency’s contrary finding, resting on substantially overlapping evidence, did not support limitations preventing Plaintiff from performing her own occupation.

What did the court decide, and what happens next?

The court denied Lincoln’s motion for judgment on the administrative record, granted Plaintiff’s motion in part, and vacated the January 5, 2023 denial. It also denied Plaintiff’s motion to strike a defense exhibit, holding that an exhibit attached to a response memorandum is not a “pleading” subject to a motion to strike under Rule 12(f). On remedy, the court chose remand over an award of benefits, reasoning that the defects in Lincoln’s process warranted a renewed and reasoned review but that the record did not establish Plaintiff’s entitlement to benefits for the disputed period. The court declined to award past-due or future benefits and denied the other benefits-dependent relief without prejudice, and it reserved any attorney’s fee request for a properly supported motion.