Jahnke v. UNUM Life Insurance Company of America

CourtDistrict Court, E.D. Michigan
DecidedSeptember 9, 2025
Docket5:24-cv-10274
StatusUnknown

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

Bluebook
Jahnke v. UNUM Life Insurance Company of America, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Marla N. Jahnke, M.D.,

Plaintiff, Case No. 24-10274

v. Judith E. Levy United States District Judge Unum Life Insurance Company of America and Provident Life and Mag. Judge Anthony P. Patti Accident Insurance Company,

Defendants.

________________________________/

OPINION AND ORDER GRANTING IN PART AND DENYING IN PART DEFENDANTS’ MOTION FOR JUDGMENT BASED ON THE ADMINISTRATIVE RECORD AND MOTION TO DIMISS PLAINTIFF’S STATE-LAW CLAIM [15] AND GRANTING PLAINTIFF’S MOTION FOR JUDGMENT ON THE ADMINISTRATIVE RECORD AND TO REVERSE THE PLAN ADMINISTRATOR’S DECISION [16]

Before the Court are Defendants’ Motion for Judgment Based on the Administrative Record and Motion to Dismiss Plaintiff’s State-Law Claim (“Defendants’ Motion”), (ECF No. 15), and Plaintiff’s Motion for Judgment on the Administrative Record and to Reverse the Plan Administrator’s Decision (“Plaintiff’s Motion”). (ECF No. 16.) For the reasons set forth below, Defendants’ Motion is granted in part and denied in part, and Plaintiff’s Motion is granted.

I. Background Plaintiff is a pediatric dermatologist who has suffered from a

variety of symptoms following the birth of her second child in June 2019. Defendants, which are two insurance companies owned by the Unum Group, initially paid Plaintiff disability benefits but terminated those

benefits on December 16, 2021, after finding that she was no longer disabled as defined by her policies as of December 1, 2021. (ECF No. 11- 16, PageID.4441, AR at 4184.) That denial led the present litigation.

When Plaintiff initially applied for benefits, she informed Defendants that she had severe nausea and vomiting during both of her pregnancies and that her second pregnancy in 2018 was particularly

difficult. (ECF No. 11-2, PageID.617, AR at 0360.) During her second pregnancy, she stopped working, was hospitalized twice, and was required to be on bedrest for 8 months. (Id.; ECF No. 11-8, PageID.2243,

AR at 1986.) After Plaintiff gave birth to her second child in June 2019, she reported pelvic pain and difficulty working for more than three hours when she returned to work in September 2019. (ECF No. 11-2, PageID.617, AR at 0360.) She limited her time at work to three hours per day for two to three days a week. (Id.) In October 2019, Plaintiff claimed

disability benefits under her policies with Defendants, citing her hyperemesis gravidarum (a severe type of nausea and vomiting during

pregnancy), pelvic floor dysfunction, sacroiliac joint disfunction, and generalized weakness. (Id. at PageID.407, AR at 0150.) Plaintiff made claims under two policies, both of which are

governed by the Employee Retirement Income Security Act of 1974 (“ERISA”). 29 U.S.C. § 1001, et seq. Her policy with Defendant Unum Life Insurance Company of America (“Unum”) was a long-term disability

benefit policy (the “Unum Policy”) available through her employer, Henry Ford Health System. (ECF No. 11-1, PageID.212, AR at 0002.) The Unum Policy defines disability as occurring when:

-you are limited from performing the material and substantial duties of your regular occupation due to your sickness or injury; and - you have 20% or more loss in your indexed monthly earnings due to the same sickness or injury (Id. at PageID.226, AR at 0016 (emphasis in original).) Through Defendant Provident Life and Accident Insurance Company (“Provident”) Plaintiff had a second policy (the “Provident

Policy”). Under that policy, [r]esidual Disability or residually disabled, during the Elimination Period, means that due to Injuries or Sickness: 1. you are not able to do one or more of your substantial and material daily business duties or you are not able to do your usual daily business duties for as much time as it would normally take you to do them; 2. you have a Loss in Monthly Income in your occupation of at least 20%; and 3. you are receiving care by a Physician which is appropriate for the condition causing disability. We will waive this requirement when continued care would be of no benefit to you. After the Elimination Period has been satisfied, you are no longer required to have a loss of duties or time. Residual Disability or residually disabled then means that as a result of the same Injuries or Sickness: 1. you have a Loss of Monthly Income in your occupation of at least 20%; and 2. you are receiving care by a Physician which is appropriate for the condition causing the Loss of Monthly Income. We will waive this requirement when continued care would be of no benefit to you. (ECF No. 12-1, PageID.6056–6057, AR at 0011–0012.) The elimination period for the Provident Policy is 365 days. (Id. at PageID.6049, AR at

0004.) Although Defendants initially approved Plaintiff’s claims and

began paying them, they later followed up and stated that they would continue paying her benefits but would do so “under Reservation of Rights,” meaning they would continue making payments on a contingent

basis until the completion of their review of her claims. (ECF No. 11-7, PageID.1805, AR at 1548.) Plaintiff has received a variety of medical treatments and

evaluations during the period relevant to this litigation. On November 1, 2019, she had an x-ray of her sacrum and coccyx, which revealed degenerative changes within the sacroiliac joint, the spine, and the pubic

symphysis. (ECF No. 11-8, PageID.2247, AR at 1990.) On November 23, 2019, Plaintiff’s treating physician, Dr. Lauren Eichenbaum, who works in physical medicine and rehabilitation, stated

that Plaintiff had physical restrictions and limitations requiring her to avoid prolonged sitting and standing, avoid lifting over 10 pounds, and limit sitting and standing to 20 minutes at a time. (ECF No. 11-2, PageID.350, AR at 0093.) Dr. Eichenbaum noted that she would reevaluate Plaintiff the following month. (Id.) A nurse clinical consultant

for Unum agreed with Dr. Eichenbaum, noting that despite an unknown etiology, the recommended restrictions and limitations were supported.

(ECF No. 11-7, PageID.1604–1605, AR at 1347–1348.) On December 16, 2019, along with referencing several improvements, Dr. Eichenbaum noted that Plaintiff’s strength was “5/5

throughout all four extremities” but stated that she should get an MRI and continue with physical therapy. (ECF No. 11-7, PageID.1636, AR at 1379.) On January 20, 2020, however, Dr. Eichenbaum’s notes indicate

that Plaintiff had difficulty transitioning from sitting to standing, going up stairs, and lifting her children, though Plaintiff’s pain had moderately improved. (Id. at PageID.1634, AR at 1377.) By March 27, 2020, Plaintiff

had begun pool therapy with minimal improvements, and she continued to report physical difficulties. (Id. at PageID.1633, AR at 1376.) Plaintiff decided to change doctors and informed Defendants she

was dissatisfied with Dr. Eichenbaum. (Id. at PageID.1828, AR at 1571.) COVID had interrupted Plaintiff’s physical therapy and had forced her to confer with Dr. Eichenbaum remotely. (Id.) Despite that, Dr. Eichenbaum called Plaintiff in May 2020 and stated that she “couldn’t see justifying her being out [of the workplace] beyond 06/01/20.” (Id.)

Plaintiff found this shift to be sudden and unsupported, so she reached out to Defendants to find out what information they would need if she

switched to a new doctor. (Id.) Defendants provided Plaintiff with the information she requested. (Id. at PageID.1829, AR at 1572.) Plaintiff began to see Dr. Laura Mattson, who works in physical

medicine and rehabilitation. Dr.

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