In a recent case, Trahan v. United of Omaha Life Insurance Co., No. 2:21-CV-02281, 2022 WL 710436 (W.D. La. Mar. 9, 2022), the plaintiff alleged that he was disabled due to high blood pressure and anxiety. He filed a claim with his employer’s disability insurer only to have the claim denied. The plaintiff alleged that his high blood pressure and anxiety were connected to the high stress of his job. The insurer argued that his blood pressure was sufficiently controlled with medication and that his anxiety was not  sufficient to interfere with the essential duties of the plaintiff’s occupation. The plaintiff took blood pressure medication and a benzodiazepine for anxiety.

The claimant appealed the denial of his claim, providing several affidavits, a strong statement from his doctor, and new medical records. The insurer’s appeal department upheld the denial on appeal. In cases governed by the Employee Retirement Income Security Act, exhaustion of administrative remedies, such as appeals provided for by insurance policies, is required.  At that point, the plaintiff filed suit.

The court agreed with the insurer that plaintiff’s blood pressure issue was not sufficiently severe to be disabling. However, applying de novo review, the court found that plaintiff’s anxiety, as well as resulting anxiety medication side effects, rendered the plaintiff disabled from his occupation within the meaning of the policy. Unfortunately for the plaintiff, because the court found his only disability was due to a mental condition, this limits his benefits to only two years. Most employer-sponsored disability plans contain this two-year limitation for mental conditions or some similar limitation.

After deciding the plaintiff was eligible for benefits, the court remanded the case to the insurance company to determine how long the plaintiff was disabled and how much money he is due.