Black v. Unum Life Insurance Company of America

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Black v. Unum Life Insurance Company is a legal case where Catherine A. Black challenged Unum’s denial of her long-term disability benefits. A federal court found that Unum did not provide a full and fair review under the Employee Retirement Income Security Act (ERISA) because its internal nurse, instead of a qualified professional, reviewed Black’s appeal. As a result, the court remanded the case to Unum for a proper review, rather than awarding benefits. 

• Background: After surgery, Catherine A. Black developed severe headaches, dizziness, and vertigo, leading her employer’s plan administrator, Unum, to initially approve her long-term disability claim.
• Denial: In September 2021, Unum denied Black’s claim, asserting she was no longer disabled. Black’s internal appeal was also denied, a decision that was based on the review of a Unum nurse.
• Court ruling: In February 2024, the U.S. District Court for the Northern District of Texas found Unum failed to provide a full and fair review as required by ERISA.
  • The court determined that relying on an internal nurse, who was not qualified to assess the specific medical conditions, was a procedural violation.
  • The court also stated that the denial was based on an improper deference to the initial decision without a new, independent, and qualified medical opinion during the appeal process.
• Outcome: The court granted Black’s motion for partial summary judgment and remanded the case back to Unum for a proper review by a qualified healthcare professional. The court did not order Unum to pay the benefits at that time.
• Fifth Circuit appeal: The case continued, and in July 2025, a Fifth Circuit panel upheld the district court’s order to remand the case to Unum. They noted that Unum’s medical experts concluded Black could not perform sedentary work, but Unum had denied the claim based on a lack of evidence supporting her inability to perform such work.