Court concludes that woman capable of part-time work with medical restrictions is not "disabled" under ERISA policy

Karen McClain sued to reinstate her ERISA long-term disability benefits after her employer's LTD plan ruled that she was not "disabled."  McClain established that she was only released for part-time work with significant medical restrictions as a result of a compression fracture at L-1 and degenerative disc disease, and claimed that by any reasonable analysis, she was "disabled" from work. 

The ERISA plan administrator pointed to plan language that defined "disabled" as being "totally and continuously unable to engage in any occupation or perform any work..." and the trial court upheld the denial of benefits.  The Sixth Circuit focused on the plan language and its limited power to overturn a plan decision, and concluded that the plan's ruling was not "arbitrary or capricious."