Court Orders Insurer to Review Denial of Ark. Woman’s Benefits

March 27, 2006

A life insurance company should not have discontinued disability benefits for an Arkansas woman suffering from several ailments related to a 1995 car crash, a federal appeals court panel has ruled.

The 8th U.S. Circuit Court of Appeals upheld U.S. District Judge James M. Moody’s ruling that Unum Life Insurance Company of America abused its discretion when it denied Sandra Chronister continued disability benefits.

The insurers denied further benefits for Chronister, an employee for Baptist Health, who suffered from high blood pressure, fibromyalgia, cervical arthritis and other chronic pain symptoms resulting from a car crash in 1995. Baptist Health had a group insurance policy from Unum.

The insurance company denied the benefits because they said the severity of her symptoms was not supported by objective medical evidence.

The panel, however, rejected Chronister’s argument that the federal district court did not have jurisdiction over her case because the Employee Retirement Income Security Act does not apply to church groups. Chronister had originally sued the insurance company in Pulaski County Circuit Court, but the case was moved to federal court.

The panel ruled that Chronister showed little evidence that her plan was a “church plan” since Baptist Health severed its ties to the Arkansas Baptist State Convention after 1966.

Unum said that benefits for disabilities that are based on “self-reported symptoms” are only paid for up to two years. The appeals court agreed with Moody’s ruling that Chronister’s condition did not fall under the self-reported symptom limitation because her fibromyalgia was diagnosed using a “trigger test” by a doctor.

“Chronister’s medical condition consequently does not rest primarily on self-reported symptoms,” the panel ruled.

The Appeals Court said the lower court correctly referred the matter back to Unum’s administrator.

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