Reliance Standard Prevails in Physical vs. Mental Disability Dispute After LTD Claimant’s Treating Doctors Fail to Connect Hormonal Deficits to Disabling Symptoms

When a disability insurer terminates long-term disability benefits for a physical condition but continues paying under a mental health limitation — until that benefit exhausts — the claimant faces a uniquely difficult burden on appeal. That is precisely the situation the plaintiff confronted in an ERISA disability matter, King v. Reliance Standard Life Insurance Company, No. 1:23-CV-443-GSL, 2026 WL 873872 (N.D. Ind. Mar. 31, 2026), and the outcome illustrates the evidentiary challenges that arise when a claimant’s physical and mental conditions are deeply intertwined.

Background

King worked as a Senior Care Specialist for Medtronic. In August 2018, she was diagnosed with acromegaly after physicians discovered a pituitary adenoma growing on her brain. She underwent a pituitary hypophysectomy, and while the surgery successfully removed the tumor with no recurrence, King developed a constellation of chronic and debilitating post-surgical complications, including severe fatigue, cognitive dysfunction, frequent headaches, panhypopituitarism, adrenal insufficiency, and multiple hormonal deficits involving ACTH, thyroid-stimulating hormones, Pregnenolone, and DHEA. She also suffered from Major Depressive Disorder, Social Anxiety Disorder, and Post-Traumatic Stress Disorder.

Reliance Standard Life Insurance Company (“Reliance”) approved King’s long-term disability (“LTD”) claim under the group policy issued to Medtronic in February 2019, paying benefits initially under the “Regular Occupation” standard and then, after 12 months, under the more demanding “Any Occupation” standard.

In August 2022, following a periodic review, Reliance concluded that the medical evidence no longer supported a finding of an impairing physical condition, given the absence of residual or recurrent pituitary adenoma. However, Reliance continued paying benefits, now attributing King’s disability to her major depression and anxiety disorder. Because those conditions fell under the policy’s mental or nervous disorder limitation, Reliance notified King that her benefits would terminate upon completion of 12 months of mental health-based payments — on August 17, 2023.

King appealed the termination of her physical disability benefits in July 2023, just weeks before the mental health benefits were set to expire. She submitted updated medical records, a vocational evaluation, and a favorable Social Security disability determination. Reliance failed to issue a decision or provide written notice of an extension within the 45-day period required under Department of Labor ERISA claims procedure regulations, and Reliance conceded the appeal was not timely decided. As a result, King’s administrative remedies were deemed exhausted on September 14, 2023, and de novo review applied.

The Legal Standard

Both parties filed cross-motions for judgment on the administrative record. The court applied de novo review, noting that when a plan administrator fails to timely render a decision on appeal, there is no valid exercise of discretion to which the court can defer. Under that standard, the court was required to make an independent determination — on both the legal and factual issues — of whether King was entitled to benefits under the policy.

The parties agreed on the operative question: whether, on the record as it existed through September 2023, King had established by a preponderance of the evidence that she remained disabled from any occupation on a full-time basis as a result of her physical condition. Neither party disputed that King was disabled — the dispute was whether her disabling symptoms were caused by a physical condition or a mental one.

The Court’s Analysis

The court methodically reviewed the four categories of evidence King relied upon: treatment notes from her treating physicians, medical opinion forms, the Social Security Administration’s disability determination, and a vocational evaluation.

Turning first to the treatment notes of King’s primary care physician, Dr. Jakacki, the court found that the records from the relevant period — primarily two April 2023 visits — documented significant hormonal deficits but did not establish a causal link between those deficits and King’s reported fatigue and cognitive dysfunction. The only indication of such a link was Dr. Jakacki’s recitation of King’s own self-reported symptoms. Critically, the treatment notes categorized King’s memory and cognitive complaints under the “psychiatric” heading of his examination findings — a fact the court found significant in attributing those symptoms to her psychiatric condition rather than a physical one.

Dr. Lombard’s treatment notes fared no better. The court observed that her notes from the relevant period — visits in August and December 2022, and April 2023 — documented King’s mental health symptoms, stress about her disability determination, and low physical and cognitive stamina, but never referenced her hormonal deficits or any physical mechanism causing her neurocognitive impairments. The court found no evidence in Dr. Lombard’s notes that the treatment focus had shifted from depression and anxiety to neurocognitive complaints.

The medical opinion forms from both treating doctors presented a different — and, to the court, contradictory — picture. On their March 2023 forms, both Dr. Jakacki and Dr. Lombard opined that King’s limitations were caused by a neurocognitive disorder due to a medical condition, not a mental one. The court found this conclusion to be inconsistent with their own treatment records, which consistently categorized her cognitive symptoms as psychiatric. The court quoted the Seventh Circuit’s admonition in Black v. Long Term Disability Insurance, 582 F.3d 738, 746 (7th Cir. 2009), that treating physicians cannot present one rationale in their treatment records and another in their disability claim statements. Reliance’s nurse consultant, RN Phillips, had similarly concluded in August 2022 that there was no indication of an impairing physical condition — and while King argued that Phillips improperly ignored evidence of ongoing hormonal imbalances, the court found that the treatment notes from Dr. Jakacki and Dr. Lombard did not, in fact, establish a physical cause for King’s symptoms.

The court also declined to give meaningful weight to the 2020 Social Security Administration disability determination. Not only was the decision made years before the relevant period, but the ALJ had expressly stated that because disability was established based on mental impairment alone, it was unnecessary to assess physical function. That finding, the court concluded, affirmatively undermined King’s argument.

Finally, the court rejected Reliance’s contention that King’s trip to Florida to care for her grandfather demonstrated she was not disabled. The court agreed with King that the ability to perform some activities at home does not establish the ability to perform full-time work. However, this observation did not change the outcome, because the central question remained causation — not capacity — and the vocational evaluation, though concluding King could not perform any occupation, did not address whether a physical condition was responsible for that limitation.

The Outcome

The court denied King’s motion for summary judgment and granted Reliance’s motion for judgment on the administrative record. It entered judgment in favor of Reliance, emphasizing that its ruling did not constitute a finding that King was not disabled — only that the administrative record was insufficient to establish that her total disability during the relevant period was caused by a physical condition as defined by the policy.