ERISA LTD Benefits May Cease for Failure to Provide Objective Proof of Continued Disability Required by Plan Terms

1. Introduction

Bryce Dunham-Zemberi v. Lincoln Life Assurance Company of Boston (11th Cir. Apr. 16, 2026) is an ERISA long-term disability (“LTD”) dispute arising from the termination of benefits after an initial approval. Bryce Dunham-Zemberi, a Mattress Firm store manager covered by his employer’s group LTD plan, suffered a spinal injury in a skiing accident and underwent spinal fusion surgery. Lincoln Life Assurance Company of Boston (“Lincoln”) served as the insurer/plan administrator.

The central issue on appeal was whether Lincoln was de novo wrong to terminate LTD benefits on the ground that Dunham-Zemberi failed to provide the plan-required proof of continued disability—specifically, objective medical evidence showing he remained unable to perform a material duty of his “own occupation,” agreed by the parties to include the ability to lift up to fifty pounds.

2. Summary of the Opinion

The Eleventh Circuit affirmed the district court’s judgment for Lincoln. Applying the first step of the Circuit’s ERISA review framework, the court held Lincoln’s termination decision was not de novo wrong because the plan expressly required “proof” that included objective medical evidence, and the record’s objective evidence (imaging and clinical findings) did not support restrictions preventing full-duty work.

The court rejected two core arguments by Dunham-Zemberi:

• Objective-evidence requirement: The plan language required objective medical evidence as part of “proof,” so Lincoln did not misread the plan by insisting on such evidence for continued disability.
• Insurer duty to follow up: The burden to submit proof remained on the claimant; the plan administrator had no duty to “ferret out” evidence not provided.

The court also found the materials submitted on appeal—most notably a physical therapist’s residual functional capacity evaluation and a primary care physician letter—failed to supply objective proof that he could not lift fifty pounds, because the capacity evaluation did not include objective measurements during the lifting test to substantiate the asserted lifting limit.

3. Analysis

A. Precedents Cited

1) Blankenship v. Metro. Life Ins. Co., 644 F.3d 1350 (11th Cir. 2011)

The panel relied on Blankenship v. Metro. Life Ins. Co. for the governing appellate standard: the Eleventh Circuit reviews de novo the district court’s ruling on an ERISA benefits decision, applying the same legal standards as the district court. More importantly, Blankenship is cited as the authority reaffirming the Circuit’s multi-step methodology (the Williams framework) and the instruction that if the administrator’s decision is not “de novo wrong,” the inquiry ends.

2) Williams v. BellSouth Telecommunications, Inc., 373 F.3d 1132 (11th Cir. 2004)

Williams v. BellSouth Telecommunications, Inc. supplies the “multi-step framework” for reviewing ERISA benefits determinations. The court applied only the first step—whether the decision was “wrong” under a de novo view of the plan and record—because it concluded Lincoln’s decision was correct at that threshold stage. This procedural posture is significant: by prevailing at step one, Lincoln avoided the later Williams steps that can involve deference, discretion, and conflict-of-interest considerations.

3) Heimeshoff v. Hartford Life & Accident Ins. Co., 571 U.S. 99 (2013)

The panel quoted Heimeshoff v. Hartford Life & Accident Ins. Co. for ERISA’s “written instrument” principle: once a plan exists, the administrator’s duty is to maintain the plan “pursuant to” its written terms. That framing supported the court’s plan-text-centered analysis: if the plan defines “proof” to include objective medical evidence and states benefits cease when proof of continued disability is not provided, the administrator may enforce those terms.

4) Doyle v. Liberty Life Assurance Co. of Bos., 542 F.3d 1352 (11th Cir. 2008)

Doyle v. Liberty Life Assurance Co. of Bos. was cited by analogy to validate an administrator’s reliance on objective medical evidence where the plan’s language requires it. Although Doyle involved “reasonableness review” and the instant case was resolved at the de novo-wrong step, the citation served a doctrinal role: it reinforced that identical plan language has been construed to permit an administrator to demand objective support for disability.

In effect, Doyle helped the panel answer a key interpretive dispute: whether Lincoln was entitled to require objective proof of continued disability. The court treated the plan’s “proof” definition as dispositive, with Doyle as confirmatory authority.

5) Melech v. Life Insurance Co. of North America, 739 F.3d 663 (11th Cir. 2014)

Melech v. Life Insurance Co. of North America was used to allocate the evidentiary burden. The court quoted Melech for the proposition that “satisfactory proof” language places the burden on the claimant to prove entitlement to benefits and that the administrator need not “ferret out evidence” not provided.

That principle directly defeated Dunham-Zemberi’s argument that Lincoln was required to contact his providers (e.g., because the physical therapist invited questions) to cure gaps in objective support.

B. Legal Reasoning

1. Start with plan text (ERISA “written instrument”). The plan conditioned benefits on Lincoln’s receipt of “Proof” of disability and required that proof to include (among other items) “test results, x-rays and/or other forms of objective medical evidence.” It also stated monthly benefits cease when the claimant “fails to provide Proof of continued Disability.”
2. Define the disabling requirement. Disability was tied to inability to perform “material and substantial duties” of the claimant’s “own occupation” as performed in the national economy. The parties agreed lifting up to fifty pounds was material and substantial.
3. Evaluate whether the record contained objective proof of continued inability to lift fifty pounds. The court emphasized imaging and clinical findings from the orthopedic surgeon (no complications; strength and reflexes largely normal), plus contemporaneous notes indicating the back was “healed/stable” and the pain psychologist observed “no pain behaviors.” Two physiatrist file reviewers concluded the records did not support restrictions or limitations and supported full-time capacity.
4. Reject claimant’s “objective evidence” proffer as insufficient. The physical therapist’s residual functional capacity evaluation was not treated as establishing an objective maximum lifting limit because, as described by the court, it did not record objective measurements (the opinion focuses on heart rate measurement occurring before lifting, not during the lifting tasks). The primary care physician letter added no independent objective basis; it essentially reiterated the evaluation. An earlier Lincoln-commissioned review was temporally limited and did not address the relevant later period.
5. Apply Williams step one: not de novo wrong → affirm. Because Lincoln’s decision aligned with the plan’s proof requirements and the objective record did not substantiate ongoing restrictions, the court ended the analysis at step one and affirmed.

C. Impact

Although designated “NOT FOR PUBLICATION,” the decision is instructive within the Eleventh Circuit for how courts may treat:

• Continued-proof clauses: Plans that explicitly condition ongoing benefits on continued submission of proof—especially proof defined to include objective medical evidence—create a recurring evidentiary obligation for claimants, not merely an initial eligibility hurdle.
• Objective medical evidence provisions: Where the plan defines “proof” to include objective evidence, a claimant’s subjective reports, provider opinions untethered to objective findings, or functional testing that lacks documented objective measurements may be deemed inadequate.
• No duty to develop the claimant’s record: The court reaffirmed that administrators are not required to chase missing evidence when the plan places the proof burden on the claimant.
• Functional capacity evaluations in practice: The opinion signals that not every FCE/RFC evaluation will be treated as “objective” merely because it is performed by a clinician; the methodology and documented measurements matter.

For future litigants, the case underscores a practical lesson: when a plan requires objective proof, continued benefits may turn on whether the claimant can produce testing or measurements that directly map onto the job’s material duties (here, lifting thresholds), not merely generalized pain complaints or conclusory work restrictions.

4. Complex Concepts Simplified

ERISA § 1132(a)(1)(B)

The statute that lets a plan participant sue to recover benefits due under the plan, enforce rights under the plan, or clarify rights to future benefits.

“Written instrument” rule (29 U.S.C. § 1102(a)(1))

ERISA plans must be in writing; courts and administrators generally must follow the plan’s written terms as the starting point for deciding benefit eligibility.

“Own occupation” and “material and substantial duties”

“Own occupation” is the job as normally performed in the national economy (not necessarily the claimant’s exact employer-specific role). “Material and substantial duties” are core job tasks that cannot be reasonably removed or modified.

“Proof” and “objective medical evidence”

“Proof” is whatever the plan defines it to be. In this plan, proof must include objective support such as tests, imaging, or other objective medical evidence—not just a doctor’s statement.

De novo review and “de novo wrong”

“De novo” means the court independently evaluates whether the administrator’s decision was correct under the plan and record. Under the Eleventh Circuit’s Williams framework, if the administrator’s decision is not “de novo wrong,” the court affirms without moving to later steps.

“Ferret out evidence”

A shorthand for the principle that, where the plan places the burden on the claimant to provide proof, the administrator is not required to investigate on the claimant’s behalf to fill evidentiary gaps.

5. Conclusion

The Eleventh Circuit’s decision reinforces a plan-centered rule: where an ERISA LTD plan conditions ongoing benefits on submission of continued “proof” that includes objective medical evidence, benefits may be terminated if the claimant fails to produce objective support for continued functional restriction tied to material job duties. By applying the first step of Williams v. BellSouth Telecommunications, Inc. as reiterated in Blankenship v. Metro. Life Ins. Co., the court affirmed solely because Lincoln’s decision was not de novo wrong—highlighting the decisive role of plan language, the claimant’s proof burden (as emphasized in Melech v. Life Insurance Co. of North America), and the court’s willingness to scrutinize whether proffered functional testing actually supplies objective substantiation.