Does Long-Term Disability Have to Be Tied to a Work-Related Injury?

Employees in Chicago and around the rest of Illinois often ask if eligibility for long-term disability insurance requires suffering an injury on the job. Workers’ Compensation covers most on-the-job injuries. Most long-term disability insurance policies do not require you have suffered an on-the-job injury. Most insurance policies insure you if you cannot work due to any illness or injury. But plans are free to draft their own terms, and some plans, under some circumstances, may require you be disabled from an on-the-job injury. A recent case highlights an example of such an uncommon plan provision.

In Lane v. Structural Iron Workers Local No. 1 Pension Trust Fund, 74 F.4^th 445 (7^th Cir. July 17, 2023), Lane worked as a union iron worker until a combination of injuries left him unable to continue working. The Structural Iron Workers Local No. 1 Pension Trust Fund provided a disability pension, but tied the proof required to the number of pension credits earned. For participants with between 5 and 15 pension credits, to be eligible for a disability pension the participant must be totally disabled by the Social Security Administration (“SSA”), and the disability must be “the result of an accident sustained while on the job and employed by a Contributing Employer as an Iron Worker.” Lane had 9 credits, subjecting him to this additional requirement. Lane was adjudicated totally and permanently disabled by SSA, but the SSA award letter did not explain why Lane was disabled. Lane did not submit the SSA determination letter explaining the rationale for finding him disabled. Lane submitted doctor letters explaining he suffered an on-the-job injury to his shoulder and knee in 2014 that never fully healed, but nothing concrete tying his current disability to his 2014 on-the-job injury. The Pension Plan denied Lane’s claim and his appeal, after which Lane sued under ERISA § 502(a).

The United States Court of Appeals for the Seventh Circuit reviewed the case after the District Court ruled in the Pension Plan’s favor. The appellate court affirmed the district court’s ruling. Given the plan vested the Trustees with discretionary authority, they were entitled to interpret the plan as requiring the reason for the SSA award of total and permanent disability be an on-the-job injury. The Pension Plan obtained a medical consultant opinion that there was no concrete proof tying Lane’s disability to his alleged 2014 injury to his shoulder and knee. The Trustees even considered other evidence, such as Lane’s doctors’ opinions and his medical records, and found insufficient evidence to tie his disability to his 2014 on-the-job injury. Under deferential review, the court held this was sufficient to deny benefits.

If you have a claim for long-term disability benefits, contact a skilled ERISA long-term disability attorney today.