ERISA-Sixth Circuit Holds That Plaintiff’s Medication and Treatment Plan Constitutes Objective Findings Of Disability

In Corey v. Sedgwick Claims Management Services, Inc., No. 16-3817 (6th Cir. 2017), Plaintiff Bruce Corey worked as a machine operator in Eaton Corporation’s Northern Ohio factory.  Corey has long suffered from cluster headaches— extremely painful attacks that strike several times per day for weeks on end.  In 2014, Corey applied for short-term disability benefits under Eaton’s disability plan after a bout of headaches forced him to miss work.

After granting a period of disability, the third party administering Eaton’s disability plan discontinued benefits because Corey failed to provide objective findings of disability.  Under the plan, “[o]bjective findings include . . . [m]edications and/or treatment plan.” Corey’s physicians treated his headaches by prescribing prednisone, injecting Imitrex (a headache medication), administering oxygen therapy, and performing an occipital nerve block.

In analyzing the case, the Sixth Circuit Court of Appeals (the “Court”) said that it must decide whether Corey’s medication and treatment plan satisfy the plan’s objective findings requirement. The Court held that it does, and therefore reversed the district court’s contrary decision.

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