Shaw v. AT&T Umbrella Benefit Plan, No. 14-2224 (6th Cir. 2015)Annotate this Case
Shaw, a 39-year-old male Michigan Bell customer service representative, stopped working because of chronic neck pain. Shaw was covered under the AT&T Midwest Disability Benefits Program, under which short-term disability (STD) wage replacement benefits are available for up to 52 weeks for employees with “sickness, pregnancy, or an off-the-job illness or injury that prevents [him] from performing the duties of [his] job (or any other job assigned by the Company for which [he is] qualified) with or without reasonable accommodation.” After STD benefits run out, an employee may be eligible for long-term disability (LTD) benefits for illness or injury that prevents the applicant from engaging in any occupation or employment (with reasonable accommodation), for which he is qualified or may reasonably become qualified based on education, training or experience. Shaw received STD benefits, but was denied LTD benefits because “[c]linical information does not document a severity of your condition(s) that supports your inability to perform any occupation” and that a job specialist identified three alternative occupations that he was qualified to perform. The district court rejected Shaw’s suit under the Employee Retirement Income Security Act. The Eighth Circuit reversed, stating that Shaw demonstrated that he was denied benefits to which he was clearly entitled.