Unum Wins Appeal Over Self-Reported Symptoms in Disability Plan

Unum Life Insurance Co. of America properly terminated the disability benefits of a sociology professor with chronic fatigue and fibromyalgia, the First Circuit said Wednesday, in an opinion upholding the insurer’s practice of limiting benefits for conditions with self-reported symptoms.

An insurer can’t require objective evidence of diagnoses that can’t be objectively verified—including fibromyalgia and chronic fatigue syndrome—but it’s reasonable to require objective evidence of how these conditions limit a claimant’s ability to function, the U.S. Court of Appeals for the First Circuit said, reiterating its 2003 holding in Boardman v. Prudential Ins. Co. of Am.

The dispute turns on ...