Annette McEachin, a human resources manager, was covered under a long-term disability policy issued by Reliance Standard Life Insurance. After a car accident in February 2017, McEachin stopped working and was approved for disability benefits due to “head, neck, back pain, and headaches due to whiplash/post-concussion syndrome.” A second car accident in December 2017 aggravated her condition. In 2019, McEachin also began seeking behavioral health treatment following the death of her son.
Termination and Reinstatement of Benefits
Reliance Standard terminated McEachin’s benefits in October 2020, citing that there was supposedly insufficient medical evidence. However, after an appeal and submission of additional medical records, Reliance Standard reinstated her benefits in November 2020, finding that she was totally disabled. The insurer reversed its decision again in April 2021 and terminated benefits, finding that McEachin’s physical condition had improved and claiming that she had exhausted the 24-month limit on mental health benefits.
Court Challenges the Insurer’s Decision
McEachin filed a lawsuit in the United States District Court for the Eastern District of Michigan, Southern Division, arguing that her physical impairments continued to prevent her from performing her job duties and that the mental health limitation was misapplied. RSLI countered that McEachin’s condition had improved by early 2021, citing medical evaluations that indicated she could purportedly perform sedentary work with accommodations.
Court’s Decision and Analysis
The court agreed with parts of Reliance Standard’s findings but concluded that the insurer failed to show that McEachin’s disability benefits were initially awarded due to mental impairments:
“Reliance has not shown that, at any point during the period in which it paid benefits, McEachin’s
physical disability was insufficient to render her totally disabled. And, as Reliance concedes,
McEachin is now precluded from work due to a mental impairment. Accordingly, McEachin has not exhausted the 24-month cap on benefits due to a mental impairment, and that period began to run on April 1, 2021 when Reliance determined both that McEachin was no longer disabled due to a physical condition, and was disabled due to a mental condition.”
As a result, the 24-month cap on mental health benefits did not begin to run until April 2021. The court ordered RSLI to pay benefits until that cap was reached, provided McEachin remained disabled due to a mental condition.
Was Your Long-Term Disability Claim Denied?
If you’ve had your long-term disability benefits denied or terminated, contact the Ortiz Law Firm for a free case evaluation. Whether your claim involves physical injuries, mental health issues, or a combination of conditions, we’re here to help you fight for the benefits you deserve. Call (888) 321-8131 to schedule a free case evaluation today.
Disclaimer: This case was not handled by disability attorney Nick A. Ortiz. The court case is summarized here to give readers a better understanding of how Federal Courts decide long-term disability ERISA claims.
Here is a PDF copy of the decision: McEachin v. Reliance Standard