A Later Diagnosis Needs a Clear Connection to Your Work Limitations
A diagnosis can bring clarity after months of unexplained symptoms, sometimes after an insurer has already stopped paying disability benefits. A recent decision illustrates the next challenge: showing how the diagnosis explains the inability to perform the work covered by the policy when benefits ended.
In Syed v. Unum Life Insurance Company of America, a California federal court ruled for Unum and upheld its termination of a corporate lawyer’s long-term disability benefits. The court awarded no benefits and ordered no remand. Its decision turned on the evidence connecting the claimant’s conditions to her occupational limitations.
The claimant stopped working at Cooley in May 2023 amid depression and anxiety. Unum approved benefits in October 2023, then terminated them effective April 12, 2024. Records preceding termination described improvement and stable, manageable symptoms, with largely normal mental-status findings. Although treating providers supported disability, the court found their explanations did not adequately establish functional limitations or reconcile contrary contemporaneous records.
The administrative appeal included later medical opinions addressing POTS, dysautonomia, and chronic fatigue syndrome/myalgic encephalomyelitis, along with treating-provider letters and accounts from the claimant, a friend, and her sister. Unum upheld the termination. Reviewing the administrative record de novo, the court independently considered whether the claimant had proved disability by a preponderance of the evidence.
The policy focused on the substantial and material acts the claimant routinely performed for her employer, with reasonable continuity. The court expressly considered her actual Cooley duties. It did not substitute a generic, less demanding job.
The court recognized that a later diagnosis may explain an earlier disability and cannot be rejected solely because it is retrospective. But a diagnosis alone did not establish that the claimant met this policy’s disability definition in April 2024. The court found that the later specialist’s explanation did not persuasively reconcile tilt-test results at the upper end of normal, and the record did not indicate that the specialist had considered the contemporaneous psychiatric notes.
For claimants, the practical lesson is to ask treating clinicians to explain the connection between the medical condition, the relevant dates, and the actual work. Which duties could not be sustained? What clinical findings or documented symptoms support that conclusion? How often did limitations occur, and how long did they last? If earlier notes described improvement, did that improvement restore the ability to work with reasonable continuity—or did substantial limitations remain? Those are practical questions suggested by this decision, not a universal evidentiary checklist.
The same care applies to daily activities. Here, personal accounts weakened arguments based on social gatherings, but did not overcome the court’s concerns about the medical functional evidence. The decision does not establish that attending a gathering means someone can sustain employment, or that POTS, chronic fatigue, or mental-health conditions cannot be disabling.
A later diagnosis can matter. Its value in an appeal depends on a supported explanation of what it reveals about the claimant’s ability to work during the disputed period. Feden Law Group welcomes inquiries from people seeking a consultation about a denied or terminated ERISA disability claim.
Related reading: Why a lawyer’s actual occupational duties matter in an Unum LTD claim.
This article provides general information, not legal advice. The applicable policy and the evidence in an individual claim affect the analysis.