Sixth Circuit Affirms Unum’s Denial of Long-Term Disability Benefits to Nursing Assistant with Lingering COVID-19 Symptoms

In Goodwin v. Unum Life Ins. Co. of Am., No. 24-3321, —F.4th—-, 2025 WL 1403640 (6th Cir. May 15, 2025), the Sixth Circuit upheld Unum’s denial of long-term disability benefits to Plaintiff Goodwin, a part-time nursing assistant, under an ERISA-governed plan. Applying an “abuse of discretion” standard to evaluate the reasonableness of the denial, the court found that Unum’s decision was neither procedurally nor substantively unreasonable. This decision highlights the difficulties claimants experience in pursuing disability benefits when the standard of review is for abuse of discretion.

Plaintiff, employed at Fisher Titus Hospital, contracted COVID-19 in December 2020, resulting in significant health issues, including persistent shortness of breath, chest pain, and subsequent diagnoses such as POTS. Initially, Unum approved her short-term disability benefits, which extended from January to June 2021, reaching the policy’s cap. However, when Plaintiff applied for long-term disability benefits, Unum denied the claim, citing a lack of substantive evidence supporting continued disability. Despite ongoing symptoms, Unum relied on medical reviews indicating Plaintiff’s capability to resume work-related activities.

In reviewing the district court’s affirmation of Unum’s denial, the Sixth Circuit employed an “abuse of discretion” standard, given the ERISA plan’s delegation of discretionary authority to Unum. The court focused on two primary aspects: procedural and substantive reasonableness.

The court assessed whether Unum engaged in reasoned decision-making. Plaintiff contended that Unum ignored substantial evidence of her disability, failed to justify its shift from granting short-term to denying long-term benefits, favored its file reviewers over her treating physicians, and operated under a conflict of interest. The court, however, found these arguments unpersuasive. Unum’s evaluative process included a comprehensive consideration of all pertinent medical evidence, including Plaintiff’s POTS diagnosis and other test results. The transition from short-term to long-term benefits denial was justified by new medical opinions and evaluations obtained during the long-term assessment phase, which were absent during the short-term benefit period.

Addressing the weight of medical opinions, the court emphasized that Unum is not obliged to prioritize treating physicians’ opinions over those of independent reviewers. Notably, Nurse Practitioner Heidi Gast, who assessed Goodwin in person, had advised a return to work, counterbalancing other medical opinions. Regarding the conflict of interest, the court acknowledged Unum’s dual role as payor and administrator but noted the absence of concrete evidence demonstrating that this conflict tainted the decision-making process.

Regarding the substance of Unum’s decision, the court found that the denial was backed by substantial evidence within the administrative record, including documentation of Plaintiff’s ability to engage in physical activities and normal test outcomes. The opinions rendered by Unum’s medical reviewers, which deemed Goodwin capable of resuming her occupational duties, further substantiated the denial. Judgment affirmed.