On July 26, 2002, Lee Williams, a truck driver for SYSCO since late 1994, became sick and was diagnosed later that year with chronic fatigue syndrome (CFS). As a truck driver, Mr. Williams was required to:
- Continuously lift, bend, and carry up to 20 pounds;
- Frequently climb stairs, pull, push, reach, grasp, sit, stand, walk, finely manipulate, and lift up to 50 pounds; and,
- Occasionally climb ladders, kneel, twist, stoop, and lift 100 pounds.
After applying for disability benefits in February 2003, Aetna denied Mr. Williams’ claim for long-term disability benefits on May 12, 2003, after obtaining a physical demand analysis that outlined Mr. Williams’ job duties and an Attending Physician Statement (APS) completed by the specialist who diagnosed Mr. Williams with CFS. Aetna also had a physician review Mr. Williams’ application and the rest of his file to determine Mr. Williams’ restrictions and limitations. This physician reviewer believed that the information provided did not indicate enough impairment to justify disability benefits.
In denying disability benefits, Aetna claimed that Mr. Williams had not shown how his subjective symptoms prevented him from performing his job. The policy defined disabled as being unable to perform the material duties of the employee’s occupation and having earnings of less than 80% of pre-disability earnings.
Mr. Williams appealed this denial on September 10, 2003, by having his treating physician submit a functional capacity questionnaire completed on August 11, 2003, which stated that although Mr. Williams had improved, he was still unable to return to work. Aetna denied this appeal on January 9, 2004, for lack of sufficient evidence to show Mr. Williams could not do his job as a truck driver.
On July 28, 2004, Mr. Williams informed Aetna that he had been awarded Social Security Disability Insurance (SSDI). Mr. Williams then filed suit. The disability benefits plan continued to argue that the evidence submitted by Mr. Williams was insufficient to show Mr. Williams could not do his job. Specifically, the functional capacity questionnaire was not fully completed by the doctor, so it appeared that a full functional capacity evaluation had not been done. Despite the physician’s statement that Mr. Williams was severely limited by fatigue, the doctor did not detail how Mr. Williams was limited from performing his job. As a result, the court held that the plan had not acted improperly in denying Mr. Williams his disability benefits.
See Williams v. Aetna Life Ins. Co., No. 06-3824, 2007 U.S. App. LEXIS 25515 (7th Cir. Nov. 1, 2007).