In an ERISA long-term disability claim, a later support letter may carry less weight when the treatment notes do not document the same severity, symptoms, and work limits. In Bachand v. Reliance Standard Life Insurance Co., decided September 15, 2026, a federal district court upheld Reliance Standard’s termination of LTD benefits after reviewing the record de novo.
Why the contemporaneous notes mattered
Anna Bachand worked as a research and development engineer and developed autoimmune hepatitis. Reliance approved benefits after a significant 2023 flare involving excessive fatigue, abnormal liver testing, and medication changes. By late 2023 and early 2024, however, clinical notes described improving test results, tapering off prednisone, and reports that she was doing well or feeling better, while some fatigue and muscle aches continued.
During the appeal, Bachand and a treating physician described fatigue, tinnitus, headaches, body aches, medication side effects, and an inability to sustain full-time work. The court found that the later letter and questionnaire included symptoms and restrictions that were absent from, or insufficiently developed in, the contemporaneous notes. The physician’s failure to return several calls from Reliance’s reviewing doctor was another case-specific factor the court considered.
The court accepted that subjective symptoms can support total disability. Its conclusion rested on the lack of contemporaneous evidence showing that the reported symptoms reached work-precluding severity when benefits ended. It denied Bachand’s motion for judgment and granted Reliance’s motion.
Address the definition that controls now
The policy changed its disability definition after twelve months of benefits. The later standard required inability to perform a suitable occupation in the national economy, rather than only the former job. The court found that the physician’s letter focused largely on travel, meetings, lifting, and other demands of Bachand’s prior work. It did not adequately explain why she could not perform the suitable sedentary work identified in the vocational review.
Build functional detail throughout the claim
Treatment records can document more than diagnosis and test results. For fluctuating symptoms such as fatigue or pain, useful notes may address frequency, duration, triggers, recovery time, medication effects, and the ability to sustain attendance, pace, concentration, sitting, standing, and activity. A later opinion should reconcile improvement language and explain any change in restrictions.
Claimants and physicians should also review the plan’s current definition of disability and the occupations identified by the insurer. The opinion should connect supported limits to those duties. Bachand does not establish that subjective symptoms require laboratory proof, that treating opinions are categorically disfavored, or that a missed reviewer call defeats a claim. It is a district-court decision applying de novo review to one plan and one record.
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