In Craig Robertson v. Principal Life Insurance Company, Plaintiff, a National Account Sales Manager with XPO Logistics in Phoenix, Arizona, became disabled in July 2016 after severely injuring his left foot. His request for short-term disability benefits was granted. In October 2016 he filed a claim for long-term disability (LTD) benefits, but in November 2017, that claim was denied.
Plaintiff argued on administrative appeal that he could not perform the material duties of his own occupation, one of which was to travel and meet face-to-face with clients. Principal countered by saying his job was sedentary and travel was optional, so he was not disabled. After exhausting his administrative remedies, Plaintiff filed this ERISA action. According to the Court, the case raises one main issue: “Whether Principal applied the correct definition of ‘Own Occupation’ under the terms of the policy.”
The U.S. Court for the Northern District of California held in favor of Plaintiff ruling that “the record supports a conclusion that Prudential Life abused its discretion by defining Robertson’s occupation as sedentary and therefore denying his claim. Accordingly, judgment will enter in Robertson’s favor.”
Principal Abused its Discretion in its Interpretation of Policy Language
Robertson contended that his job was not sedentary and travel was required. Principal argued that according to the policy definition of own occupation, it could rely on the Occupational Analysis and Labor Market Survey, which defined the duties of a “National Sales Account Manager” as sedentary.
The Court disagreed and noted that the policy itself states that the Own Occupation is “the one the member is routinely performing when the Disability begins.” As such, Principal could not ignore Plaintiff’s actual job duties at the time of his disability. After careful analysis of the policy language, the Court noted that to ignore the actual job duties of claimants when assessing whether or not they are disabled “defies common sense.” Therefore, Plaintiff’s “actual job requirements must be taken into account” when determining if he is unable to perform the material duties of his own occupation.
Principal Abused its Discretion by “Giving Inadequate Consideration” to Significant Evidence that Plaintiff’s Job was Not Sedentary
In his claim for LTD benefits, Plaintiff stated that, among other things, his job required him to travel 4-6 days a month. His supervisor said that was not required and he could do his job at the home office. The supervisor said that Plaintiff was “permitted to travel” because of his experience and the relationships he had in California, but that traveling for the job was optional.
Contrary to the report of the supervisor, the Director of Human Relations of Plaintiff’s employer sent Principal numerous communications verifying that Plaintiff’s job description listed, “Must be able to travel within assigned territory without restriction.” Based on this, and other supporting evidence, the Court concluded principal abused its discretion in determining Plaintiff could perform the duties of his sedentary job and that travel was optional. “Accordingly, Robertson is disabled under the terms of the policy at issue and is entitled to benefits.”
This case was not handled by our office, but we believe it can be instructive for those who are dealing with insurance companies who are categorizing their job descriptions incorrectly. For questions about this case, or any aspect of your disability claim, contact one of our disability attorneys at Dell & Schaefer.