Evans v. LINA – LINA Denies Disability Benefits To Wireline Operator With Severe Back Pain

The plaintiff, Heath Evans, was employed by Schlumberger Technology Corporation. Evans worked as a wireline operator, a role the Department of Labor classified as requiring very heavy physical labor. Evans suffered a workplace injury to his back in November 2013, leading to significant back pain and functional limitations. He underwent two surgeries, one in 2014 and one in 2015. Despite these surgeries, Evans continued to experience intense back pain, particularly with physical activities involving lifting, bending, twisting, and prolonged sitting or standing.

The defendant in the case is Life Insurance Company of North America (LINA).

Note: LINA is one of the largest disability insurance companies in the United States. LINA used to be a subsidiary of Cigna, and LINA is now a New York Life Insurance Company subsidiary.

LINA initially approved the LTD claim and paid benefits for years. However, it conducted a review of the claim in 2020. Upon review of the claim, LINA made a decision that Mr. Evans was no longer disabled within the definition of disability in the plan and terminated benefits.

Mr. Evans then filed an internal appeal against this decision. Additional medical records and statements, including those from Evans’s treating physicians, were reviewed during the appeal process. Despite this additional information, LINA upheld its initial decision to terminate and deny the claim, finding that the evidence did not support a disability as defined by the plan.

Mr. Evans then filed an ERISA lawsuit in the United States District Court for the Northern District of Alabama. Mr. Evans argued that LINA’s decision to terminate his disability benefits was wrong and that the opinion of Dr. Estwanik, who suggested symptom exaggeration, should be ignored as it was not supported by other medical evidence. Mr. Evans also questioned the validity of using Waddell signs to determine malingering.

LINA’s primary argument was that the medical evidence did not support Heath Evans’ disability claim under the insurance plan’s terms. Specifically, LINA contended that the medical records, including evaluations by non-treating physicians and the results of functional capacity evaluations, indicated that Evans could perform sedentary work; therefore, Mr. Evans was not disabled as defined by the policy. This argument was based on analyzing medical opinions and the nature of Mr. Evans’ reported symptoms and abilities.

The court did not find Mr. Evans’s arguments compelling enough to overturn LINA’s decision and ruled in favor of LINA. The decision was based on the administrative record, which included conflicting medical opinions about Mr. Evans’s ability to work.

The court found persuasive the opinions of non-treating physicians Dr. Estwanik, Dr. Dominitz, and Dr. Carabello, who indicated that Mr. Evans’s pain levels were not as severe as claimed and would not preclude him from sedentary work. In contrast, Mr. Evans’s treating physician, Dr. Mensah, concluded that Evans was disabled based solely on self-reports of pain.

“Drs. Estwanik, Dominitz, and Carabello relied on objective medical evidence such as imaging studies, the success of Mr. Evans’s two surgeries, physical examinations, and review of Mr. Evans’s prior medical records. This contrasts with the medical opinions  Mr. Evans provided from treating physician Dr. Mensah, which concluded that Mr. Evans is disabled solely based of self-reports of pain.”

The court also considered that Evans’s daily living activities were consistent with an ability to perform sedentary work:

“Further, Mr. Evans’s daily living activities-including the ability to drive, do light housework, and generally care for himself-are consistent with Dr. Dominitz’s opinion that Mr. Evans can perform sedentary work that corresponds with his education and experience.”

In conclusion, the court granted LINA’s motion for judgment on the administrative record. It denied Evans’s motion, finding that Evans did not continue to be disabled as defined by the Plan.