The Eighth Circuit Court of Appeals has upheld a decision by Unum Life Insurance Company of America to terminate Andrew Halloran's long-term disability benefits. The ruling, filed on August 28, 2026, affects Halloran, who argued that he was unable to work due to medical issues stemming from a shoulder injury. This case highlights the complexities surrounding disability insurance claims and the standards that determine eligibility for benefits.
Andrew Halloran, a former sheet metal fabricator, sued Unum after the company ended his long-term disability benefits. The dispute arose when Unum determined that Halloran was no longer considered disabled under the policy's definition. The case reached the Eighth Circuit after Halloran lost in the lower court, where a judge ruled in favor of Unum.
The conflict began when Halloran suffered a left shoulder injury in October 2019. He underwent surgery and received short-term disability benefits, which later transitioned to long-term benefits. Initially, the policy defined “disabled” as being unable to perform his regular occupation. However, after 24 months, the definition changed to include any gainful occupation for which he was reasonably fitted by education, training, or experience.
In June 2020, Halloran's doctor reported that he could perform sedentary work, which requires mostly seated tasks with some light lifting. Despite ongoing pain and further injuries, Halloran's medical evaluations consistently indicated that he could perform some form of work. In April 2022, Unum notified Halloran that his benefits would be terminated because he was deemed not disabled under the new definition.
The Eighth Circuit judges, including Chief Judge Colloton and Circuit Judges Gruender and Kobes, reviewed the case. The court noted that Halloran had not provided sufficient evidence to prove he was unable to perform any gainful occupation. The ruling stated, “Halloran was not precluded from performing the duties of alternative, gainful occupations,” affirming the lower court's decision.
The court's opinion emphasized that Halloran's doctor had consistently stated he could engage in sedentary work. Even after Halloran submitted additional medical documentation, Unum's evaluations maintained that he was capable of performing such work. The court concluded that the district court had acted correctly in its review of the evidence and did not commit legal errors in its findings.
This ruling has significant implications for individuals navigating disability insurance claims. It underscores the importance of medical evaluations and the definitions used in insurance policies. The decision may influence future cases involving similar disputes over disability benefits, particularly regarding how courts interpret medical evidence and the standards for determining disability.
Looking ahead, Halloran has the option to appeal this ruling to the U.S. Supreme Court, but it is unclear if he will pursue that route. The case serves as a reminder of the challenges faced by those seeking disability benefits and the rigorous standards they must meet to prove their claims.