The US Court of Appeals for the Eleventh Circuit has affirmed that Life Insurance Company of North America lawfully ended a former Lowe’s employee’s long-term disability benefits, finding the insurer’s termination decision fell well within the broad discretion ERISA affords plan administrators. The per curiam ruling rejected every argument Marcy Dunn raised on appeal, offering claims teams a fully reasoned look at what a defensible termination file looks like under arbitrary-and-capricious review.
A Car Crash, Hip Surgery, and a Benefit Cut at the Two-Year Mark
The case reached the United States Court of Appeals for the Eleventh Circuit on appeal from the United States District Court for the Northern District of Georgia, D.C. Docket No. 2:24-cv-00064-RWS, and was decided by a panel of ROSENBAUM, GRANT, and LUCK, Circuit Judges.
Six years after the crash that first injured her, Dunn stopped working and applied for long-term disability benefits, citing osteoarthritis in her right hip and pain in her legs and back that had been aggravated by later hip surgery. She then sued LINA under the Employee Retirement Income Security Act of 1974, alleging her benefits had been wrongfully terminated. The Lowe’s-sponsored group policy gave LINA discretionary authority “to decide questions of eligibility for coverage or benefits.” Under its terms, a claimant had to meet the policy’s definition of “disabled” initially, then satisfy a tougher test after twenty-four months, proving she was unable to perform the material duties of any occupation. LINA initially approved Dunn’s claim, but twenty-four months later, LINA terminated Dunn’s benefits.
Discretionary Language Set a High Bar for Review
Because the policy vested LINA with discretion, the termination decision was subject to an arbitrary-and-capricious standard of review — among the most deferential tests in ERISA litigation. On appeal, the Eleventh Circuit explained it must review de novo a district court’s ruling affirming a plan administrator’s benefits decision, applying that same deferential standard, citing Blankenship v. Metro. Life Ins. Co., 644 F.3d 1350, 1354 (11th Cir. 2011). Under that framework, LINA’s decision needed only a reasonable basis to survive — a bar the panel found satisfied in No. 25-12108, filed 08/27/2026, which the court affirmed as neither arbitrary nor capricious.
Four Doctors, Two Vocational Assessments, One Reasonable Basis
LINA’s file leaned on multiple independent inputs rather than a single opinion. Its termination decision cited findings that her surgeon opined that she could perform a sedentary job, and it weighed a vocational assessment identifying two alternative occupations in Dunn’s area — information clerk and gate guard — that both paid enough and matched her physical restrictions. Dunn appealed LINA’s termination decision, prompting a further round of evaluation before the insurer upheld its original call. Reviewing that record, the Eleventh Circuit found it reasonable for LINA to rely on the findings of four medical professionals, together with the independent medical examination and the two vocational assessments, to conclude Dunn could perform sedentary jobs in her area. The full evidentiary chain is laid out in the panel’s published opinion.
Six Arguments, Six Rejections
Dunn gives six reasons why the district court erred in affirming LINA’s termination of benefits, and the panel disposed of each. On the medical evidence, the court held it was reasonable for LINA to rely on this evidence in terminating Dunn’s benefits. On bias, Dunn argued that Drs. Kornfield, Abramowitz, and Weston were biased because they were paid by LINA — an argument the panel did not credit. Dunn also raised LINA’s structural conflict of interest as both the entity that pays out to beneficiaries from its own assets and the one deciding eligibility, citing Levinson v. Reliance Standard Life Ins. Co., 245 F.3d 1321, 1326 (11th Cir. 2001). The court acknowledged the conflict but found it did not tip the outcome, noting LINA has taken active steps to reduce potential bias and to promote accuracy, per Metro. Life Ins. Co. v. Glenn, 554 U.S. 105, 117 (2008). A favorable Social Security determination did not help her case either: the Social Security Administration found that she was disabled, but the panel held that claims under ERISA and the Social Security Act are not coextensive, citing Black & Decker Disability Plan v. Nord, 538 U.S. 822, 832–34 (2003). Finally, the court turned away Dunn’s procedural objection that Dunn argues that she had no opportunity to testify before the district court, since ERISA review is generally confined to the administrative record.
Where the Ruling Leaves ERISA Claims Administration
The decision adds to a body of Eleventh Circuit precedent favoring administrators that build a multi-source record before terminating benefits — a contrast to disputes elsewhere over how far carriers can go in discovery, illustrated by one court’s recent pushback in an excess-layer disclosure dispute. It also arrives as courts keep testing the statutory carve-outs the industry relies on, following a state high court’s ruling denying producers a consumer-fraud exemption in a separate matter. And it lands amid continued repositioning of long-duration risk books, with some carriers choosing to cede long-term care exposure through reinsurance rather than manage it in-house.
For claims teams, the lesson is procedural discipline. The district court granted judgment on the administrative record for LINA the first time around, and the district court properly granted judgment on the administrative record for LINA, we affirm, the panel wrote in closing. Carriers that combine independent medical review, vocational analysis, and a documented internal appeal continue to fare well when the reasonableness of that file is tested on appeal.
