Court Upholds Principal Life's Denial of Extended Disability Benefits
In Peterson v. Principal Financial Group, plaintiff injured her back in a car accident and subsequently underwent a spinal fusion. She was awarded 24 months of disability when she was unable to return to her own occupation as a Target employee. After 24 months, the definition of disability changed to requiring her to be disabled from any job “that provides 128% or more of the disability benefit.” Principal refers to these as “extended disability.” After evaluating her medical and other records, Principal denied her application for extended disability.
After exhausting her administrative appeals, Peterson filed this ERISA lawsuit. The court upheld Principal’s denial of extended benefits concluding that, “Principal’s determination that Plaintiff was not entitled to extended disability benefits was based on substantial evidence and is therefore reasonable.” She raised several issues in the lawsuit, all of which the court determined had no merit. Two of them required a deeper analysis.
There Was Substantial Evidence to Show Peterson Could Work at a Sedentary Level
The Colorado federal district court evaluated all the evidence presented to Principal which resulted in its denial including:
- One of Peterson’s treating physicians, Dr. Lair, reported she would be able to return to work with vocational training in another field.
- Peterson had a B.A. in psychology and was able to attend post-graduate classes and work as an intern, amounting to 50 hours of activity a week, in an effort to meet her goal as a school counselor.
- A functional capacity evaluation (FCE) showed she was able to perform “light or sedentary work full-time.”
- Her surgeon, Dr. Weider, reported her symptoms and diagnosis “to be of relative low-severity,” and her cervical range of motion was normal.
- Her pain was controlled with Percocet.
- A surveillance video showed she was capable of “more activity than she had reported.” She was able to carry her child and “turn, squat, and bend while placing him into and removing him from his car seat.”
The court found Principal acted reasonably in denying the application for benefits, noting, “The relevant inquiry is not whether Principal’s conclusion was the best one, but rather whether Principal’s conclusion was a reasonable one—even if on the low end of reasonableness.”
There Was Substantial Evidence That Jobs Were Available That Paid 128% of Peterson’s Disability Benefit.
Following Principal’s determination that Peterson qualified for sedentary work, the burden shifted to her to prove no such work existed for which she was “reasonably fitted by education training or experience” that would pay her $24,222.72 per year. Principal suggest four different jobs available to her that, according to the requirements of the plan, she “could become qualified ‘by education, training, or experience.'”
Since Principal’s determination that she could qualify for these jobs, the court held that she Principal’s determination that she was “not entitled to extended disability benefits was based on substantial evidence and is therefore reasonable.”
This case was not handled by our office, but we think it can be instructive to those struggling to obtain disability benefits when required to prove their inability to work in “any occupation.” For information about disability benefits, call one of our lawyers for a free evaluation.
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Policy Holder Rating
Sorry, Principal. My residual and renewal commissions aren't "earned"
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Principal will do anything not to pay
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Principal is absolutely ridiculous. I'm in financial harship after not receibing my full pay from work and exhausting my long term sick
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Principal owes me 60k
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I lost everything when Principal terminated my benefits without calling or emailing me
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I cant but feel I am being starved out and given the runaround.
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Principal owes me 4k
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I've never worked with people that are so obviously stalling before. Bunch of crooks
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Q: Can Principal deduct my social security payment from my monthly Principal disability benefit payment?
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Q: Why did Principal not back me when Social Security did?
Q: What is the difference between time period of the claim while approved and the time period of the claim while denied?
Q: Will Principal harass me if I don't accept their buyout? And, is it standard for a buyout to be lower than the full benefit paid over time?
Q: Can Principal's independent physician determine what I can and cannot do?
Q: Do I have to pay Principal back once I receive back pay from SSA?
Q: Can Principal take away my deceased husband's 3 month survivor benefit? They justified it saying he was eligible for SSDI when he didn't even apply.
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