Hansen v. UNUM Life Insurance Company of America

CourtDistrict Court, D. Colorado
DecidedJuly 9, 2025
Docket1:23-cv-02288
StatusUnknown

This text of Hansen v. UNUM Life Insurance Company of America (Hansen v. UNUM Life Insurance Company of America) is published on Counsel Stack Legal Research, covering District Court, D. Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hansen v. UNUM Life Insurance Company of America, (D. Colo. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Charlotte N. Sweeney

Civil Action No. 23-cv-02288-CNS-JPO

J.J.H.,

Plaintiff,

v.

UNUM LIFE INSURANCE COMPANY OF AMERICA,

Defendant.

ORDER

Plaintiff J.J.H.1 brought this suit against Defendant Unum Life Insurance, alleging that Defendant unlawfully denied her long-term disability benefits in violation of the Employment Retirement Security Act of 1974 (ERISA). The administrative record and merits briefing are complete, and the parties now ask the Court to decide whether Defendant’s benefits decision was lawful. ECF No. 33 (Joint Motion for Determination on the Administrative Record). Having thoroughly analyzed the record, the parties’ briefing, and the applicable authority, the Court finds that substantial evidence supports the Defendant’s denial of Plaintiff’s benefits and thus AFFIRMS Defendant’s benefit determination.

1 In Social Security Appeals, D.C.COLO.L.APR 5.2(b) requires the Court to identify the plaintiff by initials only. The Court will do the same here and refer to Plaintiff by her initials only. 1 | BACKGROUND A. Plaintiff’s Occupation, Employer, and the Plan Plaintiff is a transactional attorney employed by an international law firm and based in its Denver office. Administrative Record (A.R.) at 251. The parties agree that her role is sedentary but requires numerous cognitive demands. /d. at 645-55. Plaintiff was, and apparently still is, a participant in the [Law Firm] and its Subsidiaries Plan, which provides short-term disability (STD) and long-term disability (LTD) benefits. ECF No. 29 at 3; ECF No. 23 (May 1, 2024 joint status report noting that Plaintiff has returned to work on a part-time basis). STD benefits are self-funded by Plaintiff's employer, and LTD benefits are funded through a group insurance policy from Defendant. ECF No. 29 at 3. The LTD Plan and group policy defined “disability” and “regular occupation” as follows: Classes 1, 2, 4, 5 and 6 » "Disability” and "disabled" mean that because of injury or sickness: 1. you cannot perform each of the material duties of your regular occu- pation; or 2. you, while unable to perform all of the material duties of your regular occupation on a full-time basis, are: a. performing at least one of the material duties of your regular oc- =o ote or another occupation on a part-time or full-time basis; an b. earning currently at least 20% less per month than your indexed pre-disability earnings due to that same sickness or injury. Note: For attorneys, “regular occupation" means the specialty in the practice of law which you were practicing just prior to the date the dis- ability started.

Id.; A.R. at 135. Plaintiff is a Class 2 employee under the Plan, eligible for a benefit of up to 50% of her monthly earnings, not to exceed $10,000 per month. A.R. at 5. B. Plaintiff’s COVID-19 Illness Plaintiff first reported COVID-19 symptoms beginning on January 13, 2022. A.R. at 360. Sometime the following week she tested positive for COVID-19. Id. at 1353 (January 18, 2022); id. at 1673 (January 20, 2022). She complained of fatigue, brain fog, confusion, forgetfulness, difficulty concentrating, difficulty planning/executing tasks, increased or abnormal heart rate, heart palpitations, chest pain, headache, lightheadedness, dizziness, dyspnea, blood pooling in her feet, abdominal pain, and diarrhea. Id. at 92, 345–46, 357, 612.

After her positive COVID-19 test, Plaintiff continued to work from home on a reduced basis. Id. at 1353–54. She did not take formal leave, and her pay was not reduced during this period. Id. at 219–34, 276. C. Plaintiff’s Short-Term Disability Benefits The Plan contained a 90-day elimination period of consecutive days of disability for which no benefit is payable. Id. at 681. During the elimination period (April 20, 2022, to July 21, 2022), the law firm offered STD, also administered by Defendant. ECF No. 26 at 5. In April 2022, Plaintiff stopped worked and submitted a claim for STD benefits based on “post-covid fatigue” and “cognitive attention deficit.” Id. at 60–66. She reported

her last day of work was April 20, 2022. Id. at 60. Dr. Karen Burnett, Plaintiff’s primary care physician, reported Plaintiff’s restrictions and limitations as the following: “unable 3 work a full day due to fatigue, difficulty concentrating, difficulty interacting with clients. Memory impairment. Standing for long periods of time.” Id. at 66. Defendant approved Plaintiff’s STD claim on April 29, 2022, effective April 22 through May 7, 2022. Id. at 877. Defendant later extended Plaintiff’s STD benefits through June 25, 2022. Id. at 880 (letter dated June 9, 2022). In the end, Defendant approved all of the STD available. A.R. at 1678 (“We acknowledge that . . . [STD] was approved through the maximum period of payment.”). D. Plaintiff’s Transition to Long-Term Disability After Plaintiff reached the maximum benefit period for STD in June 2022, Defendant transitioned her claim to a long-term disability (LTD) claim. Id. at 1678. Also in

late June 2022, Dr. Burnett provided updated restrictions and limitations permitting Plaintiff to return to work on a part-time basis beginning June 27. Id. at 185. Dr. Burnett advised that Plaintiff should work from home on a limited afternoon schedule. Id. (restricting Plaintiff to a “total of 5 hours a day starting at noon”). Dr. Burnett stated that Plaintiff’s ability to return to full-time employment was “still to be determined, awaiting evaluation by the UChealth post covid clinic” at her upcoming June 29, 2022 appointment. Id. E. Defendant’s Long-Term Disability Claim Investigation, Medical Records Review, and Initial Determination

As Defendant began its LTD claim investigation, it learned that Plaintiff was working a reduced schedule but did not have a reduction in earnings. ECF No. 29 at 5. The law firm was continuing to pay “100% of her salary until her LTD claim was approved.” A.R. at 391 (email from law firm’s HR specialist). Defendant explained that, because 4 Plaintiff had been paid in full and was not experiencing an earnings loss, she was not eligible for LTD benefits under the policy. /d. at 424. Defendant further explained that, if Plaintiff would like Defendant to consider her LTD claim, she would need to repay the law firm the money she was paid since she went out of work. /d. On August 15, 2022, the law firm confirmed it would withhold pay from her future checks to recoup the overpayment. Id. at 428. Defendant then proceeded with its LTD claim investigation. As part of this process, Defendant acquired information from the law firm about Plaintiff's job duties. Deborah Nix, a Vocational Consultant, then analyzed the material physical and cognitive requirements of Plaintiff's occupation. /d. at 645-47. Ms. Nix determined that Plaintiff's occupation was sedentary work with limited physical demand. Id. Concerning the “Mental/Cognitive Demands,” she determined the following: Dealing with People: Involves interpersonal relationships in job situations beyond receiving work instructions. Performing a Variety of Duties: Involves frequent changes of tasks involving different aptitudes, technologies, techniques, procedures, working conditions, physical demands, or degrees of attentiveness without loss of efficiency or composure. The involvement cf the worker in two or more fields may be a clue that this temperament is required. Influencing People in their Opinions, Attitudes, & Judgments: Involves writing, demonstrating, or speaking to persuade and motivate people to change their attitudes or opinions, participate in a particular activity, or purchase a specific commodity or service.

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Hansen v. UNUM Life Insurance Company of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hansen-v-unum-life-insurance-company-of-america-cod-2025.