Whether the denial of long-term disability (LTD) benefits violated the Employee Retirement Income Security Act (ERISA); Whether plaintiff demonstrated “a continuous inability” to perform the main duties of an accounts receivable manager during the plan’s elimination period

The court held that plaintiff-Tranbarger was not entitled to LTD benefits where she failed to show that she was unable to perform each of the main duties of her job as an accounts receivable manager during the plan’s six-month elimination period after her resignation. She began to suffer from various medical conditions after gallbladder surgery, including pain and chronic fatigue syndrome. She left her job and later sought LTD benefits through the disability insurance plan in which she had enrolled through her employer. Defendant-Lincoln operated the plan. To receive the benefits, she was required to “show 'total disability' such that she was 'unable to perform each of the [m]ain [d]uties of . . . her [o]wn [o]ccupation'—an accounts receivable manager—during a six-month 'Elimination Period' following her resignation.” She presented medical evidence and other evidence, including approval for Social Security disability, but Lincoln denied her claim. She sued, alleging that the denial violated ERISA. The district court ruled in Lincoln’s favor. On appeal, the court first considered whether Tranbarger was able to show that she had “a continuous inability to perform the main duties of an accounts receivable manager during the six months following her resignation[.]” It noted that this was a high bar to meet where “[e]ven one day of partial work ability during the Elimination Period is enough to defeat Tranbarger’s claim.” The court found the evidence in the administrative record as to her functional capacity was “middling.” It then concluded that she failed to meet the plan’s “rigorous standard” of continuous inability to perform the main duties of her former job through the elimination period. The court found there was “ample evidence” suggesting she could “perform some work in some instances.” Thus, even though the record made clear that she “suffered considerable pain[,]” this was not enough to “satisfy the plan’s rigid eligibility” standards. The court noted that although the Mayo Clinic diagnosed her with fibromyalgia and chronic pain syndrome, these “general diagnoses” did not answer whether she was able to work during the critical period. It also explained that a decision regarding Social Security benefits is not binding in an ERISA case. Affirmed.