ERISA

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7^th Circuit Court of Appeals

Case Name: Scott Scanlon v. Life Insurance Company of North America

Case No.: 22-1121

Officials: Rovner, Jackson-Akiwumi, and Lee, Circuit Judges.

Focus: ERISA

Scanlon, a veteran with a history of chronic pain and sleep disorders, took a leave of absence from his position as a Systems Administrator at McKesson. He made a request for adjustments in order to resume work; although McKesson granted temporary accommodations for some of his requests, not all of them were approved. Instead of returning to work, Scanlon pursued benefits for long-term disability insurance as per a group policy provided by McKesson, which was underwritten, insured, and managed by Life Insurance Company of North America (LINA).

In order to qualify as “disabled” under the policy, an employee must be incapable of carrying out the “essential duties” of their regular occupation and must earn 80% or more of their indexed earnings from that occupation. Despite Scanlon submitting examination reports, letters, and residual functional capacity evaluations from VA examinations, LINA rejected his application for benefits. LINA’s medical experts determined that Scanlon did not meet the criteria for receiving benefits.

In a legal case under ERISA, 29 U.S.C. 1132, the district court ruled that Scanlon, a military veteran, suffered from multiple chronic orthopedic and sleep disorders that caused him pain and hindered his daily life. However, the court determined that Scanlon did not qualify for benefits, as he failed to demonstrate his inability to perform the essential duties of his job. The Seventh Circuit overturned this decision. The appeals court found that the district court had made a significant error by neglecting to consider Scanlon’s incapacity to sit at his desk for the required eight hours each day, as mandated by his job. Additionally, the appeals court highlighted Scanlon’s incapability to meet the cognitive demands of his job within regular working hours and criticized the district court’s handling of specific medical records that Scanlon had provided.

Vacated and Remanded.

Decided 08/31/23

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