Standard of Review Proves Decisive as Court Affirms Unum’s Termination of Long-Term Disability Benefits

In Cunha v. Unum Life Insurance Company of America, No. CIV-24-514-R, 2025 WL 3640392 (W.D. Okla. Dec. 16, 2025), the U.S. District Court for the Western District of Oklahoma upheld Unum’s termination of long-term disability (“LTD”) benefits under an ERISA-governed plan, emphasizing that the arbitrary-and-capricious standard of review—rather than the court’s own view of the merits—controlled the outcome.

Background

Plaintiff Cunha, a former registered nurse, had received LTD benefits from Unum for more than fifteen years due to significant back and hip conditions. After the plan’s definition of disability shifted from “own occupation” to “any occupation,” Unum continued paying benefits for many years before terminating them in 2023, concluding that Cunha could perform sedentary gainful employment consistent with her education and experience.

Unum’s decision relied on updated medical records, internal nurse reviews, and a vocational assessment identifying sedentary occupations such as clerical assistant and scheduler. Although Cunha reported chronic pain and functional limitations—and had long been awarded Social Security Disability benefits—Unum emphasized the absence of recent medical evidence imposing work-preclusive restrictions.

District Court’s Analysis

The court began its analysis by emphasizing that the parties agreed the plan conferred discretionary authority on Unum, requiring review under the arbitrary and capricious standard. Under that deferential framework, the court explained, Unum’s decision had to be upheld so long as it was supported by a reasoned basis, even if other evidence in the record could support the opposite conclusion.

After conducting what it described as a “laborious” review of the administrative record, the court acknowledged that Cunha had presented meaningful evidence in support of continued disability, including her extensive surgical history, long-term receipt of benefits, ongoing pain management with narcotic medication, and prior Social Security Disability award. The court also recognized that there was evidence in the record that could have justified a finding in her favor.

Nevertheless, the court concluded that Unum’s decision was supported by substantial evidence when viewed through the proper lens. In particular, the court relied on the absence of current medical records imposing functional restrictions or limitations, noting that Cunha’s treating providers did not submit contemporaneous opinions stating that she was unable to perform sedentary work. The court found it significant that Cunha had indicated she was stable, had no planned procedures, and had not produced updated imaging or provider opinions during the appeal process despite being given additional time to do so.

The court also rejected Cunha’s argument that Unum cherry-picked the evidence or failed to adequately develop the record. While acknowledging that a 2021 form completed by a nurse practitioner supported disability, the court held that Unum did not act arbitrarily by crediting more recent records and clinical reviews suggesting improvement and stability. The court reiterated that an administrator’s decision to rely on some evidence while rejecting other evidence—even treating-source opinions—does not render a decision arbitrary and capricious.

With respect to Cunha’s Social Security Disability award, the court agreed that Unum was required to consider and address it, but held that Unum adequately reconciled the differing outcomes by explaining that the SSA decision dated back to 2009 and did not reflect Cunha’s current functional capacity. The court reiterated that continued receipt of SSDI benefits does not obligate an ERISA plan administrator to continue paying benefits where the plan’s definition of disability is not met.

Finally, the court considered Unum’s structural conflict of interest as both the insurer and administrator of the plan. While acknowledging that Unum relied primarily on internal medical and vocational reviewers, the court concluded that this factor did not outweigh the otherwise reasoned explanation for the termination, particularly where Cunha was given a full opportunity to submit additional evidence and declined to do so.

Taken together, the court held that although reasonable minds could differ on the ultimate question of disability, Unum’s decision fell within the bounds of reasonableness required under arbitrary-and-capricious review.

Key Takeaway: Standard of Review Was Outcome-Determinative

In a notable concluding passage, the court made explicit that the standard of review—not the persuasiveness of competing evidence—dictated the result:

“This is not an easy case and, although the Court may have reached a different decision in the first instance, the Court is constrained by the applicable standard of review. That standard asks whether there is a reasoned basis for the decision, not whether the decision is the best or most logical one.”

Because Unum identified more than a scintilla of evidence supporting its determination and provided a coherent explanation for reversing course after years of payments, the court held it could not substitute its judgment for that of the administrator. Judgment was therefore entered for Unum.

Why It Matters

Cunha underscores a recurring theme in ERISA litigation: when discretionary authority exists, claimants face a steep uphill battle on judicial review—even in close cases with sympathetic facts and long benefit histories. The decision serves as a reminder that, under deferential review, courts may affirm benefit terminations they might not have reached themselves if reviewing the claim de novo.