Robin Doyle was a registered nurse working for ChoicePoint Services, and filed a claim for short-term disability benefits on January 30, 2004. She based her disability on a number of conditions, including anal fissure, enlarged internal hemorrhoids, and external anal skin tags. She underwent surgery on February 10, 2004, in an effort to solve these health problems.
Liberty Life granted the maximum term of short-term disability benefits, which ran through May 9, 2004. Liberty Life then undertook to assess whether Ms. Doyle would qualify for long-term disability benefits after the expiration of the short-term disability benefit period. Based on a review of her records by an independent physician hired by Liberty Life, the insurance company denied Ms. Doyle her long-term disability benefits.
After her claim was denied, Ms. Doyle treated with a rheumatologist who diagnosed her with fibromyalgia. Armed with this new diagnosis, Ms. Doyle appealed the denial of her claim. Liberty Life denied the claim for long-term disability benefits, and Ms. Doyle filed suit.
The trial court found in favor of Liberty Life, and upheld the decision to deny disability benefits to Ms. Doyle, who appealed the decision of the trial court. The appellate court reversed the trial court, stating that the trial court had erred in not requiring Liberty Life to show that there was no conflict of interest for the carrier in both making the decision to deny disability benefits and being responsibility for paying disability benefits if it found that Ms. Doyle was disabled.
Ultimately, the appellate court sent the case back to the trial court to re-review the evidence in light of the conflict of interest. Ms. Doyle will therefore have another opportunity to have the trial court review her case and claim for long-term disability benefits.
See Doyle v. Liberty Life Assurance Co. of Boston, 511 F.3d 1336 (11th Cir. 2008).