In Chamness v. Liberty Life Assurance Company of Boston, plaintiff James Chamness, a board-certified pediatrician who is also a pediatric sleep specialist, applied for long term disability benefits. He claimed he suffered from both physical and mental disorders. Specifically, he was diagnosed with asthma, irritable bowel syndrome, coronary artery disease, sleep apnea and gastroesophageal reflux disease.
Plaintiff was also diagnosed with mental disorders of depression and obsessive-compulsive disorder along with a tendency for perfectionism. Dr. Dumerauf, a board-certified psychiatrist who treated Chamness for several years, stated that Chamness was limited in the “practice of medicine due to impaired concentration and fatigue.”
After having its consultants review plaintiff’s medical records, Liberty denied plaintiff’s claim stating that he was not physically or mentally impaired. Plaintiff appealed and, after exhausting his administrative remedies, filed this ERISA lawsuit.
The court agreed with Liberty that plaintiff did not qualify for long term disability benefits based on his alleged physical disabilities. But, the Michigan Federal District Court found in plaintiff’s favor and held that he was entitled to long term disability benefits due to his mental disabilities. The Court concluded, “Chamness has established that he is entitled to long term disability benefits for a mental health disability.”
Plaintiff Was Not Eligible for Long Term Disability Benefits for His Physical Disorders
Despite plaintiff’s numerous physical health issues, a review of the medical records did not support his claim for long term disability benefits. Neither of his treating physicians placed any limitations on his activity except to state that he should not drive if he was excessively sleepy. The Court concluded nowhere in the record was there any opinion supporting his claim that “he cannot perform his duties of his own occupation because of his physical ailments… Accordingly, Chamness has not established that he suffers a physical disability such that he would be entitled to long-term benefits under the Plan.”
Plaintiff is Entitled to Long Term Disability Benefits for His Mental Health Disability
Plaintiff claimed that he was disabled due to his depression and anxiety and that these psychological impairments limited his ability to concentrate and caused him to have memory problems. His long-term treating psychiatrist, Dr. Dumerauf, reported that plaintiff’s stress, health complications and medications “elevated his stress level as his work was affected.” As for limitations, Dumerauf checked a box which stated “Marked Limitations: Patient is unable to engage in stress situations or engage in interpersonal relations.”
The Court noted that there was a conflict between Dumerauf and Liberty’s consultants who reviewed the files. The Court also noted that although it was not legally required to give deference to the treating physician’s opinion, a second evaluation confirmed Dumerauf’s conclusion. A reviewing consultant hired by Liberty found plaintiff was not impaired and could return to work.
Ultimately, the court found in favor of plaintiff. Liberty relied on file reviews which, according to Sixth Circuit precedent, are “questionable” when the claim “involves a mental illness component.” In addition, at least one of Liberty’s reviewers either ignored or misstated the record. Based on the record, the Court reversed the decision of Liberty and ordered it to approve plaintiff’s claim for long term disability based on his mental health disability.
This case was not handled by our office, but we believe it can be helpful to professionals with physical and mental disorders who are struggling to have their insurers approve their claim for long term disability benefits. If you have any questions about this case, or about your own disability case, contact one of our disability attorneys at Dell & Schaefer for a free consultation.