When “Sedentary” Isn’t the Whole Job: California Court Restores 20 Years of ERISA Disability Benefits Reliance Standard Cut Off

In Cyr v. Reliance Standard Life Insurance Company, No. 2:23-cv-06286-DSF-RAO, 2026 WL 2056667 (C.D. Cal. July 15, 2026), United States District Judge Dale S. Fischer, following a bench trial on the administrative record, found in favor of a long-term disability claimant whose ERISA benefits Reliance Standard Life Insurance Company had paid for two decades before terminating them. Reviewing the denial de novo, the court held that Plaintiff had proven by a preponderance of the evidence that she could not perform the material duties of her regular occupation, both because of cognitive impairments and because she could not meet the physical requirements of even a sedentary job.

What ERISA disability benefits were at issue?

Plaintiff had worked as a Vice President of Administration at a subsidiary of Channel Technologies, Inc. until she stopped working in 2000. Her employer maintained an ERISA-governed long-term disability plan funded through a group policy issued by Reliance Standard, which was also the named claims administrator. The policy paid a monthly benefit to an insured who was totally disabled as the result of a covered sickness or injury, defined as being unable, as a result of injury or sickness, to perform the material duties of her regular occupation. The policy treated partial disability, meaning the inability to perform some material duties on a full-time basis or all of them on a part-time basis, as total disability.

Plaintiff first submitted a claim in 2000 based on a back condition arising from an earlier automobile accident. Reliance Standard approved the claim and began paying benefits in 2001. Over the following twenty years, Plaintiff asserted additional grounds for disability, with diagnoses including cervical disc disease, multiple sclerosis, complex regional pain syndrome, seizure disorder, strokes, and traumatic brain injury. Reliance Standard continued to find her totally disabled throughout that period, and as late as a 2014 review acknowledged her multiple sclerosis and seizure disorder and found that a lack of consistent work function was supported.

Why did Reliance Standard terminate the claim?

After transferring the claim to its Extended Duration Unit and requesting updated records, Reliance Standard terminated benefits in a June 2021 letter. A staff medical specialist reviewed the file and, relying in part on a progress note from orthopedist Dr. Premjit Deol stating that Plaintiff had been doing “remarkably well” and had skied for about five hours, and on an attending physician statement from primary care physician Dr. Barbara Hrach indicating Plaintiff could sit for ten hours at a time, concluded that Plaintiff was capable of sedentary work. Because Reliance Standard classified her pre-disability occupation as sedentary, it determined she no longer met the definition of total disability. The termination letter did not address Plaintiff’s cognitive abilities.

Plaintiff, her physicians, and her attorneys submitted extensive additional material over the following year. Dr. Hrach retracted her earlier statement about sitting for ten hours, explaining after speaking with Plaintiff that Plaintiff could not sit for any length of time, and opined that Plaintiff’s physical and mental condition had worsened since the onset of her disability. Dr. Deol corrected his earlier note, stating it had been a misdocumentation and that Plaintiff had been active for five hours over the course of a month rather than skiing five hours continuously, and opined that she was permanently disabled. Updated statements from neurologist Dr. Michael Gibbs and physician Dr. Kelley Glancey documented seizures, memory loss, speech difficulty, and severe limitations on sitting. Reliance Standard commissioned a paper review by Dr. Norman Burns, who addressed only whether Plaintiff retained sedentary physical capacity and concluded she did. Reliance Standard upheld the termination in a July 2022 final denial, again without making any determination about Plaintiff’s cognitive function or the cognitive demands of her occupation.

What standard of review applied?

The court reviewed the denial de novo, examining the administrative record without deference to Reliance Standard’s conclusions. Under de novo review, Plaintiff bore the burden of proving by a preponderance of the evidence that she was disabled under the terms of the plan, meaning she had to show not merely the existence of an impairment but that the impairment was disabling. The court considered only the rationales Reliance Standard relied on in denying benefits and declined to adopt new rationales that Plaintiff had no opportunity to address during the administrative process.

How did the court treat the competing medical opinions?

The court noted that it was not required to give special deference to treating physicians based on their status as treating physicians, but that courts generally give greater weight to doctors who have actually examined the claimant than to those who only review the file, especially where the reviewer is employed by the insurer. Applying that principle, the court found the in-person evaluations and observations of Drs. Hrach, Glancey, Gibbs, and Deol more persuasive than Dr. Burns’s paper review. The court observed that these physicians had treated Plaintiff over many years, saw her frequently and consistently, and did not waver in their recommendation that she cease work. It acknowledged that several of the post-termination opinions contained changes characterized as corrections to earlier documentation, but found them consistent both with the physicians’ pre-termination opinions and with one another.

The court assigned less weight to one document, a July 2022 letter signed by Dr. Gibbs, after Reliance Standard produced extra-record evidence showing that the letter had been drafted by Plaintiff’s counsel and signed by Dr. Gibbs without changes. The court did not question whether Dr. Gibbs agreed with the letter’s contents, but found it lacked the same assurance of reflecting his independent medical judgment as his clinical notes and attending physician statements.

Why did the court find Plaintiff disabled?

The court’s central conclusion was that Reliance Standard and its reviewing physician had failed to apply the policy’s actual standard. By assessing only whether Plaintiff could perform the duties of a generic sedentary job, rather than the specific material duties of her own occupation including its non-physical duties, Reliance Standard did not measure disability as the policy required. Although Plaintiff’s occupation did involve a sedentary level of exertion, its material duties were broader, encompassing managing departments, formulating plans and policies, directing accounting and budget functions, coordinating operational activities, and developing long-range goals. The court found that Plaintiff’s documented cognitive symptoms, including seizures, memory loss, speech difficulty, loss of awareness, migraines, and medication side effects, rendered her unable to meet the cognitive demands of that occupation. It concluded that memory loss and speech difficulty impaired her ability to manage departments and coordinate operations, and that loss of awareness impaired nearly all functions requiring high-level cognition.

The court further found that Plaintiff had established she could not perform even the physical requirements of a sedentary occupation. Her physicians regularly reported severe pain, and the court noted that disabling pain cannot always be measured objectively and that the record did not establish the unreliability of Plaintiff or her physicians. Dr. Hrach indicated that Plaintiff could occasionally lift only up to one pound, less than the ten pounds required for sedentary work. The court also treated Reliance Standard’s own payment of benefits for over two decades, which required its own repeated findings of total disability, as support for Plaintiff’s claim.

The court rejected the significance Reliance Standard placed on Plaintiff’s recreational activities, noting that the insurer never explained how skiing, hiking, golfing, sewing, or pool therapy demonstrated an ability to perform the material duties of her occupation, particularly given that the job required cognitive capacity rather than physical exertion. Finally, because Reliance Standard had not raised Plaintiff’s credibility as a ground for denial in either denial letter, the court held it was precluded under Ninth Circuit precedent from relying on inconsistencies or post-termination revisions to suggest Plaintiff was not a reliable narrator.

What did the court decide on the extra-record evidence?

On de novo review, the court explained, it may consider evidence outside the administrative record only where circumstances clearly establish that additional evidence is necessary for an adequate review. Of the extra-record material Reliance Standard offered, the court admitted only the draft letter counsel sent to Dr. Gibbs, because that document bore on the Gibbs letter’s credibility. It admitted a short excerpt of Dr. Gibbs’s deposition offered by Plaintiff in response to that same evidence, and declined to admit the parties’ remaining submissions, including additional deposition testimony, a supplement to the administrative record, and Reliance Standard’s request for judicial notice of a California statute, as unnecessary to its review.

Weighing the record as a whole, the court found that the evidence favored Plaintiff and that she had met her burden of establishing entitlement to long-term disability benefits. The court directed Plaintiff to submit a proposed judgment and set a schedule for objections and for briefing on attorneys’ fees and costs.