Long-Term Disability Policy Relies on Job Functions in National Economy Not Duties Specific to One Employer

Juanita Nichol’s job at Peco Foods, Inc. as a Hazard Analysis Critical Control Point (HACCP) Coordinator exposed her to temperatures around 40 degrees as a routine part of her job in the chicken processing plant. When she developed a circulatory disorder, Raynaud’s phenomenon, she could no longer work in cold environments and filed for long-term disability benefits. Reliance Standard Life Insurance Company issued the policy to Peco. Reliance denied Nichol’s claim based on its findings that while she might not be able to perform her job for a meat packing plant, she could still perform the “material duties of the Regular Occupation” as defined by how that job “is normally performed in the national economy”. A district court reversed Reliance’s denial of benefits and ordered the company to pay Nichols past and future benefits. The Fifth Circuit Court of Appeals reversed that decision. Find all the details of the discussion here: http://www.ca5.uscourts.gov/opinions/pub/18/18-60499-CV0.pdf