Evans v. Life Insurance Company of North America

Plaintiff Evans, a former employee covered under an ERISA-governed group long-term disability plan, sued Life Insurance Company of North America (LINA) after the insurer terminated disability benefits. Evans claimed total disability due to fibromyalgia, chronic fatigue, and cognitive impairments. LINA conducted a review, including medical file analysis and surveillance, concluding Evans retained sedentary work capacity and no longer met the plan's definition of disability. Evans exhausted administrative appeals and filed suit in federal court. On June 7, 2023, the court applied the arbitrary-and-capricious standard, finding LINA's termination decision was supported by substantial evidence and reasoned analysis, rejecting claims of procedural irregularities and bias.

The court granted summary judgment in favor of Life Insurance Company of North America, holding that the benefit termination was not arbitrary and capricious and that the administrative process was fair.

Whether LINA abused its discretion in terminating disability benefits, and whether the administrative record supported a finding that Evans could perform sedentary work under the plan's definition.

The case underscores the significant hurdles claimants face under the ERISA abuse-of-discretion standard, as courts rarely overturn insurer decisions. It renewed criticism of deferred review standards and the limited scope of admissible evidence, highlighting the power imbalance between individual plaintiffs and large insurers in long-term disability disputes.