Lincoln Life Wins Disability Appeal as Judge Weighs ERISA Review

Lincoln Life & Annuity Co. of New York defeated a disability benefits appeal by an accounts receivable manager experiencing pain and fatigue, with one Sixth Circuit judge using the case to urge a new judicial review standard in ERISA cases.

Vickie Tranbarger presented only “middling” evidence that she was unable to perform the main duties of her job during the six months following her resignation, the US Court of Appeals for the Sixth Circuit said Thursday. Tranbarger’s disability policy with Lincoln Life required proof of continuous disability during this six-month period, and she failed to meet this “rigorous” standard, the ...