Bryce Dunham-Zemberi worked as a store manager for Mattress Firm, a role that required lifting up to fifty pounds as a material and substantial duty. After suffering a back injury in a skiing accident and undergoing spinal fusion surgery, he received long-term disability benefits administered by Lincoln Life Assurance Company. The plan defined disability as the inability to perform the material duties of one's own occupation and required the submission of specific proof, including objective medical evidence, to continue receiving benefits. Eight months after his surgery, his orthopedic surgeon noted no complications and rated his strength as normal, referring him to a pain psychologist who observed no pain behaviors. Despite Dunham-Zemberi's continued complaints, a reviewer hired by Lincoln found no clinical reason to preclude full-time work. Consequently, Lincoln terminated his benefits in February 2021, stating he failed to provide proof of continued disability. Dunham-Zemberi appealed, submitting a capacity evaluation and a physician's letter, but the district court granted summary judgment to Lincoln, ruling that Dunham-Zemberi did not meet his burden of proof.
The Eleventh Circuit reviewed the case de novo to determine if Lincoln's decision was correct under the plan's written instrument. The court emphasized that the plan explicitly required 'objective medical evidence' such as test results, x-rays, or lab findings to prove continued disability. The court rejected Dunham-Zemberi's argument that his submitted evidence met this standard. First, the capacity evaluation from his physical therapist was deemed insufficient because, while it measured his heart rate before the test, it did not monitor his heart rate during the lifting activity, meaning there was no objective measure of his physiological response to the stress of lifting. Second, the letter from his primary care physician merely explained the capacity evaluation and offered no independent objective data. Third, an earlier medical review commissioned by Lincoln was irrelevant as it predated the period in question. The court clarified that the burden of proof lies squarely with the employee to provide the required evidence. Citing Melech v. Life Insurance Co. of North America, the court noted that plan administrators are not required to 'ferret out evidence' that the employee fails to submit. Because Dunham-Zemberi failed to provide objective medical evidence proving he could not lift fifty pounds, Lincoln's decision to terminate benefits was de novo correct.
This decision reinforces the strict evidentiary requirements of ERISA plans that mandate objective medical evidence for disability claims. Plan administrators are protected when they terminate benefits based on a lack of such evidence, provided the plan language clearly places the burden of proof on the employee. The ruling limits the ability of claimants to rely on subjective complaints or non-physiological capacity evaluations that lack real-time objective data. The case is affirmed, meaning the termination of Dunham-Zemberi's benefits stands, and no remand instructions were issued as the district court's judgment was correct.