Scanlon v. LINA Decision

​On August 31, 2023, the United States Court of Appeals for the Seventh Circuit ruled in favor of our client, a System Analyst who suffers from significant spinal pain and a sleep disorder, in Scanlon v. Life Insurance Company of North America. A district court judge had previously ruled against the client, prompting DeBofsky Law to appeal the decision to the appellate court. The court of appeals vacated the district court’s erroneous decision and remanded the matter for further proceedings.

Notably, the appellate court determined that the district court clearly erred in its assessment of a functional capacity evaluation (“FCE”) that supported the client’s long-term disability benefit claim. The appellate court was also critical of the district court’s disregard of the client’s inability to earn 80% of his earnings, which he was required to prove under his disability policy, based on his inability to sit throughout the day. Per the appellate court, “the district court failed to appropriately consider [client]’s inability to sit for extended periods of time, as required by his occupation, and did not explain how [client] can earn 80% or more of his regular income.” Likewise, the Seventh Circuit court found that the district court’s consideration of the physical and cognitive demands of the client’s occupation was erroneous because “the district court did not consider the effect [client]’s chronic sleep disorders had on his ability to perform the cognitive requirements of a Systems Analyst job.”

The precedential ruling benefits not just this client, but all disability claimants within the Seventh Circuit, which includes Illinois, Indiana, and Wisconsin, who have been wrongfully denied disability benefits due to their insurer’s or a district court judge’s inadequate consideration of FCEs and the actual demands required of their respective occupations. Shareholder Matthew Maloney briefed and argued the case before the Seventh Circuit.

Download the full version of Scanlon v. LINA Decision here

You may access the public legal opinion here