Substantial Evidence and Social Media Activity Under ERISA’s Arbitrary-and-Capricious Standard: Commentary on Eggleston v. Unum Life Insurance Co. of America

I. Introduction

This commentary examines the Eleventh Circuit’s unpublished, non-precedential decision in Yvette Eggleston v. Unum Life Insurance Company of America, No. 24-13678 (11th Cir. Dec. 3, 2025), an ERISA long-term disability (“LTD”) case arising from the termination of benefits after more than a decade of payments.

Although marked “NOT FOR PUBLICATION,” and thus not binding precedent within the Eleventh Circuit, the opinion is instructive. It illustrates:

How courts apply the Eleventh Circuit’s six-step Blankenship framework to ERISA benefit denials.
The deference courts give to plan administrators under the “arbitrary and capricious” standard when a plan grants discretionary authority.
How social media evidence and daily activities can influence disability determinations.
The limited role of treating-physician opinions in ERISA disability disputes.

At the center of the dispute is Ms. Yvette Eggleston, a clinical research nurse who stopped working in 2011 due to multiple chronic conditions and received LTD benefits for years, only to have those benefits terminated by Unum in 2022 after an investigation triggered by her social media activity. The district court upheld Unum’s decision, and the Eleventh Circuit affirmed.

II. Background of the Case

A. The Parties and the Plan

Plaintiff-Appellant: Yvette Eggleston, a clinical research nurse employed at Johns Hopkins Bayview Medical Center. Because of her employment, she participated in a group long-term disability insurance policy issued by Unum Life Insurance Company of America. The policy is an “employee welfare benefit plan” governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. § 1001 et seq.

Defendant-Appellee: Unum Life Insurance Company of America, which both insured and administered the LTD plan. Johns Hopkins delegated to Unum:

“discretionary authority to determine … eligibility for benefits and to interpret the terms and provisions of the policy.”

This discretionary clause is pivotal. Under Supreme Court and Eleventh Circuit precedent, such language shifts the judicial standard of review from de novo to the highly deferential “arbitrary and capricious” standard.

B. Policy Definition of Disability

The policy contained the common “two-tier” disability definition:

First 24 months (“own occupation” period):
Eggleston was entitled to benefits if she was:
“limited from performing the material and substantial duties of [her] regular occupation due to [her] sickness or injury.”
After 24 months (“any occupation” period):
She would continue receiving benefits only if she was:
not “able to work in any gainful occupation for which” she was “reasonably fitted by education, training, or experience on a part-time basis.”

Thus, the case involves the “any gainful occupation” phase, where the standard is significantly more demanding for the claimant.

C. Medical History and Initial Approval of Benefits

Ms. Eggleston stopped working in 2011 due to pain associated with multiple chronic conditions, developing and being diagnosed over time with:

Sciatica (2011),
Fibromyalgia (2013),
Undifferentiated connective tissue disease (2015), among others.

Unum initially approved her claim. Her providers reported that she could not stand or walk for prolonged periods, and Unum agreed that she was unable to perform the material duties of her regular job as a clinical research nurse.

When the definition of disability transitioned to the “any gainful occupation” standard after 24 months, Unum again approved continuing benefits. At that time, she had:

Elevated inflammatory markers, and
Complaints of significant joint stiffness (hands, wrists, ankles, feet).

Unum concluded:

“it is reasonable that [she] would be unable to sustain reliable work capacity at this time,”

while cautioning that:

“with medical treatment, [her] condition may improve” and it was “anticipated that [she] may regain the ability to increase [her] functional capacity in the future.”

In later years, Unum’s reviews reflected a mixed picture:

2014: Lumbar imaging did “not find significant disease”; she could sit for brief periods but “sustainability is problematic”; prognosis “guarded.”
2015: Some improvement in inflammatory markers and function, yet ongoing pain and elevated markers justified continued benefits.

After 2015, Unum conducted less frequent reviews but continued benefits, largely because treating providers repeatedly stated that she could sit or stand only for 5–15 minutes at a time due to self-reported pain. At the same time, Unum’s reviews noted ongoing “potential for further improvement/stabilization.”

D. Social Media Discovery and Renewed Investigation

The dynamic changed in 2021 when Unum discovered social media posts showing Eggleston:

Operating a soul food catering business,
Traveling to St. Thomas in the U.S. Virgin Islands,
Attending a three-hour performance, and
Attending a wedding.

Unum observed that she:

“appear[ed] active with travel,” was able to “cook[] and cater[],” and could sit or stand for multiple hours for entertainment purposes.

These activities, which arguably suggested greater functional capacity than the extreme limitations reported by her providers, prompted a “harder look” at her file.

Unum’s renewed investigation included:

Status calls with Eggleston, who reported a recent flareup and fall but said she was improving.
Communications with her medical providers, who maintained she was unable to work but acknowledged improvements.
Updated diagnostics:
- Blood tests for arthritis: negative.
- Ultrasound and x-rays for joint swelling: “unremarkable.”
- No signs of acute distress or serious joint pathology.

E. Unum’s Expert Reviews and Benefit Termination

In 2022, Unum obtained multiple reviews by its medical experts, who concluded:

Her chronic conditions were “generally stable and controlled” with only “mild to moderate and intermittent” flares.
Inflammatory markers were “within normal limits.”
No evidence of significant medication changes or documentation of “severe, uncontrolled pain.”
No red, swollen, or hot joints; no significant joint erosion; no hand or finger dysfunction.

Unum also commissioned a vocational evaluation. The vocational consultant concluded that Eggleston could perform sedentary work and identified several “gainful occupations” for which she was reasonably fitted by education, training, or experience:

Triage nurse,
Utilization review coordinator,
Medical claims review nurse.

On this record, Unum determined that Eggleston no longer met the “any gainful occupation” definition of disability and terminated her benefits.

After Unum’s termination decision, Eggleston reported increased pain and restarted physical therapy for the first time in over a year. At one appointment, it emerged that she had stopped taking her medication “at various times for various reasons,” and her medication levels were “undetectable.” Those facts, however, post-dated the challenged decision and, under ERISA standards, are not part of the evidence that can justify Unum’s decision.

F. Administrative Appeal and District Court Proceedings

Eggleston administratively appealed, but Unum upheld its termination. She then filed suit in the U.S. District Court for the Southern District of Florida under 29 U.S.C. § 1132(a)(1)(B), challenging Unum’s denial of continuing LTD benefits.

On cross-motions for summary judgment, the district court:

Set out the medical history and Unum’s investigations from 2011–2020.
Noted that Unum’s “harder look” was triggered by her social media activity, which suggested meaningful functional capacity.
Recognized that treating providers’ opinions were based on self-reported pain, physical examinations, and generally unremarkable objective findings.
Emphasized that Unum’s medical experts reviewed the same records and concluded that the objective evidence did not support complete incapacity from any work.
Concluded that Unum’s decision was reasonable and supported by the record and thus not arbitrary and capricious.

Judgment was entered for Unum, and Eggleston appealed.

III. Summary of the Eleventh Circuit’s Opinion

On appeal, Eggleston argued primarily that the district court erred by not making specific findings that Unum’s opinions were “reasonable,” as required in ERISA cases reviewed under the arbitrary-and-capricious standard.

The Eleventh Circuit:

Assumed (without deciding) that Unum’s decision was “de novo wrong.”
This assumption moved the analysis to the key question of reasonableness under deferential review.
Confirmed that the plan vested Unum with discretionary authority.
Citing Kirwan and Firestone, the court agreed that the policy’s explicit grant of discretion triggered arbitrary-and-capricious review.
Applied the arbitrary-and-capricious standard at step three of the Eleventh Circuit’s six-step ERISA framework.
The court reiterated that the question is whether Unum’s decision was supported by “substantial evidence.”
Held that Unum’s decision was supported by substantial evidence.
It pointed to:
- Multiple medical expert reviews indicating stable, controlled conditions, normal inflammatory markers, and lack of severe pathology.
- Social media posts and real-world activities showing meaningful functional capacity.
- Treating physicians’ reliance on self-reported pain in the face of largely unremarkable objective findings.
Reaffirmed that administrators need not give special deference to treating physicians.
Citing Blankenship and Swaters, the court noted that Unum could reasonably credit its own experts over Eggleston’s providers.
Concluded that the district court’s reasoning was sufficient.
The court rejected Eggleston’s argument that the district court had failed to make a proper “reasonableness” finding, holding that the district court had adequately considered the competing opinions and evidence.
Affirmed without detailed conflict-of-interest analysis.
Because the decision was not arbitrary and capricious, and Eggleston did not challenge the district court’s conflict-of-interest findings, the panel did not address steps four through six of the six-step framework in detail.

The court therefore affirmed the judgment for Unum.

IV. Detailed Analysis

A. Precedents and Frameworks Cited

1. Firestone Tire & Rubber Co. v. Bruch and Discretionary Clauses

The Eleventh Circuit relies on Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (1989), which established that:

“[A] denial of benefits challenged under [§] 1132(a)(1)(B) is to be reviewed under a de novo standard unless the benefits plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan.”

In Eggleston, the plan expressly granted Unum:

“discretionary authority to determine your eligibility for benefits and to interpret the terms and provisions of the policy.”

Citing Kirwan v. Marriott Corp., 10 F.3d 784 (11th Cir. 1994), the panel had no difficulty concluding that Unum’s decisions are therefore reviewed under the arbitrary-and-capricious standard. This is a textbook application of Firestone’s rule.

2. The Eleventh Circuit’s Six-Step Blankenship Framework

The opinion applies the Eleventh Circuit’s well-known six-step framework, articulated in Blankenship v. Metropolitan Life Insurance Co., 644 F.3d 1350 (11th Cir. 2011), and restated in Alexandra H. v. Oxford Health Ins. Inc. Freedom Access Plan, 833 F.3d 1299 (11th Cir. 2016). As summarized in Alexandra H., the steps are:

Apply de novo review to determine whether the administrator’s decision was “wrong.” If not, affirm.
If the decision was de novo “wrong,” determine whether the administrator had discretion. If not, reverse.
If de novo wrong and discretion exists, determine whether reasonable grounds supported the decision (arbitrary-and-capricious review).
If no reasonable grounds exist, reverse. If reasonable grounds exist, determine whether a conflict of interest existed.
If there is no conflict, affirm.
If there is a conflict, treat it as a factor in determining whether the decision was arbitrary and capricious.

Here, the court, like the district court, assumed without deciding at step one that Unum’s benefits termination was de novo wrong, then proceeded directly to steps two and three:

Step 2: Confirmed Unum’s discretionary authority from the plan language.
Step 3: Asked whether Unum’s decision was supported by reasonable grounds, under the arbitrary-and-capricious standard.

The court’s willingness to assume de novo error and still affirm on arbitrary-and-capricious grounds underscores the power of plan-granted discretion and the deference courts afford administrators under this framework.

3. “Substantial Evidence” and the Role of Competing Medical Opinions

The court draws on two key Eleventh Circuit precedents:

Swaters v. Osmus, 568 F.3d 1315 (11th Cir. 2009)
“Substantial evidence” is defined as:
“such relevant evidence as a reasonable mind might accept as adequate to support a conclusion”—“something more than a scintilla of evidence, but something less than the weight of the evidence.”

The court further quotes Swaters for the principle that:

“the possibility of drawing two inconsistent conclusions from the evidence does not prevent an administrative agency’s findings from being supported by substantial evidence.”
Blankenship
The panel cites Blankenship for the important rule that:
- Plan administrators may give different weight to competing medical opinions without acting arbitrarily and capriciously.
- Administrators are not required to give any special deference to the claimant’s treating physicians.

In the Social Security context, courts historically gave treating physicians extra weight (“treating physician rule”). ERISA, as reaffirmed here, does not: an ERISA administrator may reasonably favor file reviewers and independent consultants over treating providers, as long as its decision is supported by substantial evidence.

4. Record-Limited Review: Glazer and Alexandra H.

Two additional precedents frame the scope of review:

Glazer v. Reliance Standard Life Ins. Co., 524 F.3d 1241 (11th Cir. 2008)
The court must determine whether:
“there was a reasonable basis for the decision, based upon the facts as known to the administrator at the time the decision was made.”
Alexandra H.
The review is confined to:
“the record before the administrator.”

These authorities explain why, although the court’s factual narrative includes some post-termination developments (like her restarting physical therapy and admitting medication non-compliance), those facts cannot be relied upon to justify Unum’s decision. The legal analysis is confined to what Unum knew when it acted.

B. The Court’s Legal Reasoning

1. Application of the Six-Step Test in Eggleston

The court’s step-by-step approach can be reconstructed as follows:

Step 1 (De novo wrong?):
The court “assume[d] (without deciding)” that Unum’s decision was de novo wrong. This assumption favors the claimant but is procedurally permissible; it allows the court to focus on the core question of reasonableness under discretionary review.
Step 2 (Discretion?):
The court held that Unum had discretionary authority because the plan “expressly provided” such authority. This invokes the arbitrary-and-capricious standard at step three.
Step 3 (Reasonable grounds?):
The heart of the opinion. The court asks whether Unum’s decision is supported by substantial evidence and thus not arbitrary and capricious. The remainder of the analysis is devoted to that question.
Steps 4–6 (Conflict of interest):
The court acknowledges in a footnote that normally it would proceed to conflict-of-interest analysis, but:
- The district court found a structural conflict (Unum both decides and pays claims) but concluded there was no evidence the conflict affected the decision.
- Eggleston did not challenge those findings on appeal.
- The panel therefore deemed the conflict-of-interest issue waived and resolved the case entirely at step three.

This structure highlights a crucial practical point: if an ERISA claimant loses at step three (arbitrary-and-capricious reasonableness), later steps rarely help unless the claimant affirmatively develops and presses a conflict-of-interest argument with record support.

2. Substantial Evidence for Unum’s Decision

The Eleventh Circuit emphasized that the record contained “competing opinions” regarding Eggleston’s disability status at the time Unum terminated benefits:

Treating Providers’ View:
They asserted that Eggleston was unable to work, basing their opinions on:
- Her self-reported pain and symptom levels,
- Physical examinations, and
- Diagnostic studies (imaging and bloodwork) that were essentially “unremarkable” during the relevant period.
Unum’s Experts’ View:
Unum’s reviewing physicians concluded, after reviewing the same records, that:
- The medical evidence did not support the treating providers’ claims of complete incapacity for any work.
- The functional limitations suggested by the providers were “overly restrictive.”
- Her conditions were stable and controlled, with lab values (including inflammatory markers) near or in normal range.

At the same time, social media posts and reported activities (travel, catering, attending lengthy events) suggested that Eggleston could sit or stand for longer than the 5–15 minute limits reported by her providers.

Given this record, the court held that Unum had a reasonable basis to:

Give greater weight to its independent reviewers and vocational evidence, and
Conclude that Eggleston could perform some sedentary gainful occupations consistent with her experience and training.

Under Swaters, the existence of another plausible interpretation (that she remained totally disabled) does not invalidate Unum’s decision as long as a reasonable mind could accept the evidence supporting Unum’s conclusion. The court stressed that:

“the possibility of drawing two inconsistent conclusions from the evidence does not prevent an administrative agency’s findings from being supported by substantial evidence.”

Hence, the fact that treating physicians continued to support disability did not make Unum’s contrary conclusion arbitrary or capricious.

3. No Special Deference to Treating Physicians

A central pillar of the court’s reasoning is its reaffirmation that ERISA plan administrators:

“may give different weight to competing medical opinions without acting arbitrarily and capriciously,” and
“need not accord extra respect to the opinions of a claimant’s treating physicians.”

This rule, drawn from Blankenship, is critical in cases involving chronic pain syndromes (like fibromyalgia) where objective tests may not perfectly correlate with subjective reported pain, and treating physicians often side with their patients. The opinion underscores that:

It is not per se unreasonable to give more weight to file reviewers, especially where objective tests are largely normal.
ERISA does not codify a “treating physician rule” similar to that once used in Social Security disability cases.

Thus, while the court acknowledges the conflict in medical opinions, it views Unum’s preference for its experts as permissible, especially where supported by objective indicators and activity evidence.

4. The Role of Social Media and Daily Activities

Although the panel does not devote a separate doctrinal section to social media evidence, it clearly accepts Unum’s reliance on Eggleston’s:

Travel,
Catering business activity,
Attendance at a three-hour show, and
Wedding attendance

as probative of “improved functional capacity.”

The district court had described social media as the “impetus” for Unum’s “harder look” at the claim. The Eleventh Circuit, in affirming, effectively approves the use of:

Online and social media posts as legitimate evidence of daily functioning.
Non-work activities (like attending entertainment events) as relevant to the ability to sustain work-like tasks, particularly sedentary work.

This carries significant practical implications:

Claimants should expect that visible online activities may be used to challenge the severity of reported limitations.
Administrators are encouraged to integrate social media evidence with medical and vocational assessments as part of a “harder look.”

Importantly, the court does not suggest that social media alone suffices. Rather, it is part of “substantial evidence” when combined with:

Stabilized objective medical findings, and
Expert medical and vocational opinions supporting work capacity.

5. District Court’s “Reasonableness” Findings

Eggleston’s principal appellate argument was procedural: she claimed the district court failed to make the necessary findings that Unum’s decision was reasonable. She contended that the court essentially accepted Unum’s conclusion without properly assessing whether it was arbitrary and capricious.

The Eleventh Circuit disagreed. It held that the district court:

Recognized the conflict in the record between treating physicians and Unum’s experts.
Described the self-reported nature of much of the treating evidence and the unremarkable objective studies.
Highlighted the social media evidence indicating substantial functional capacity.
Concluded that Unum’s decision was supported by evidence and was not unreasonable.

The appellate panel thus viewed the district court as having adequately:

Considered the totality of the record, and
Articulated a rational basis for finding Unum’s decision supported by substantial evidence.

The opinion makes clear that the district court need not use any magic words; so long as it applies the correct standard and grounds its conclusion in the evidence, its analysis will ordinarily be upheld.

6. Conflict of Interest: Not Outcome-Determinative Here

The district court found a “structural conflict of interest” — Unum both decides claims and pays benefits, which gives it a financial interest in denying claims. Under Supreme Court precedent (MetLife v. Glenn) and Eleventh Circuit law, such a conflict is a factor in arbitrary-and-capricious review.

However:

The district court saw “nothing in the record to reflect that the conflict influenced Unum’s decision.”
Eggleston did not challenge that conclusion on appeal.

Consequently, the Eleventh Circuit declined to engage in full conflict analysis (steps four through six of the framework). It emphasized that the case “rises and falls” on step three: whether Unum’s decision was arbitrary and capricious. Because it was not, the existence of a structural conflict had no practical effect in this appeal.

This reinforces two points:

Burden on claimant: The claimant must not only establish that a conflict exists but also develop evidence suggesting that the conflict manifested in biased claim administration (e.g., selective use of evidence, procedural irregularities).
Limited reach of structural conflicts: Simply being a dual-role insurer-administrator is not enough to overturn a denial where substantial evidence supports the decision and no concrete influence is shown.

C. Impact and Implications

1. For ERISA Disability Claimants

For claimants like Eggleston, the opinion is a stark reminder of how difficult it is to overturn an LTD termination where:

The plan grants the administrator explicit discretionary authority.
The administrator builds a record of:
- Multiple independent medical reviews,
- Vocational assessments, and
- Consistent, relatively benign objective findings.

Key lessons for claimants:

Objective records matter heavily.
Even when conditions such as fibromyalgia involve inherently subjective symptoms, administrators and courts will look for consistency between self-reported pain and objective indicators, or at least for coherent, longitudinal treatment records.
Social media can undermine credibility.
Publicly visible travel and business activities can be interpreted as evidence of greater functional capacity than claimed.
Long-term payments do not lock in a lifetime entitlement.
The fact that a claimant has been paid for many years does not prevent a plan from terminating benefits when it reasonably concludes that the claimant is no longer disabled.
Conflict-of-interest arguments must be developed, not assumed.
Simply asserting that an insurer has a structural conflict is rarely sufficient; claimants should highlight specific signs of bias or unfairness in the review process.

2. For Plan Administrators and Insurers

For insurers like Unum, Eggleston provides a road map for creating a defensible termination decision under arbitrary-and-capricious review:

Use independent expert reviews.
Multiple physician reviewers who carefully analyze the full file bolster the reasonableness of a decision, especially if they align in their conclusions.
Document vocational feasibility.
A vocational assessment identifying specific “gainful occupations” reasonably fitted to the claimant strengthens the argument that the “any occupation” standard is not satisfied.
Incorporate real-world functional evidence.
Surveillance and social media evidence, if consistent with other medical findings, are legitimate components of “substantial evidence.”
Acknowledge and explain conflicts in the evidence.
Administrators should explicitly discuss treating providers’ contrary opinions and explain why they are discounted (e.g., reliance on self-reporting, inconsistency with objective studies or observed activities).

By following this model, administrators can greatly increase the likelihood that their decisions will be upheld even where claimants present a sympathetic medical profile.

3. For Courts and Practitioners

For courts, Eggleston is a straightforward but useful application of existing ERISA doctrine:

It reaffirms that the six-step framework remains the governing approach in the Eleventh Circuit.
It emphasizes that courts do not re-weigh evidence but examine whether a reasonable basis exists.
It underscores that fact-intensive disputes about disability, when governed by discretionary clauses, will often result in deference to the administrator.

For attorneys representing claimants:

Build a robust, contemporaneous medical record.
Encourage treating providers to carefully document functional limitations with as much specificity and objective support as possible.
Address social media proactively.
Discuss with clients how their public activities may be perceived in light of claimed limitations.
Develop the conflict-of-interest record.
If there are procedural irregularities, patterns of selective evidence use, or other signs of bias, ensure they are well-documented in the administrative record.

For defense counsel:

Emphasize file-review thoroughness.
Demonstrating that the administrator considered all material evidence, including unfavorable evidence, is key to surviving arbitrary-and-capricious scrutiny.
Highlight objective improvement or stability over time.
Showing that disability was initially justified but later no longer supported is an effective narrative for defending a termination.

4. Broader ERISA Doctrine

While non-precedential, Eggleston fits comfortably within the broader ERISA jurisprudence:

It is entirely consistent with Firestone, Glenn, Blankenship, and related Eleventh Circuit decisions.
It illustrates the enduring power of plan-based discretion clauses.
It confirms that substantial evidence is a relatively forgiving standard for administrators.

The decision does not create new law but consolidates existing principles in a modern factual setting involving social media and long-term disability benefits.

V. Complex Concepts Simplified

A. What Is ERISA and an ERISA Disability Claim?

The Employee Retirement Income Security Act of 1974 (ERISA) sets federal standards for private employer-sponsored benefit plans, including long-term disability (LTD) plans. A lawsuit like Eggleston’s, brought under 29 U.S.C. § 1132(a)(1)(B), seeks:

“to recover benefits due” under the plan,
to enforce rights under the plan, or
to clarify rights to future benefits.

ERISA does not require any particular level of benefits but governs how plans are administered and how disputes are reviewed in court.

B. “Own Occupation” vs. “Any Gainful Occupation”

Many LTD policies have a two-stage disability standard:

Own Occupation:
During an initial period (here, 24 months), disability is defined relative to the insured’s regular job. You are disabled if you cannot perform the material and substantial duties of your own occupation.
Any Gainful Occupation:
After that, the standard becomes stricter; you are considered disabled only if you cannot work in any gainful occupation for which you are reasonably fitted by education, training, or experience.

Thus, a person might be disabled as to their original job but not disabled as to other, often more sedentary, jobs. In Eggleston, Unum accepted that she had been disabled under both standards for some years but concluded she no longer met the “any occupation” definition.

C. Standards of Judicial Review: De Novo vs. Arbitrary and Capricious

Two main standards of review apply to ERISA benefit decisions:

De Novo Review:
The court decides the issue from scratch, without deference to the administrator, based purely on the evidence. This is the default under Firestone if the plan does not grant discretion.
Arbitrary and Capricious (or Abuse of Discretion) Review:
If the plan does grant the administrator discretionary authority, the court will uphold the decision so long as it was reasonable and supported by substantial evidence, even if the court personally might have decided differently.

In Eggleston, the policy expressly gave Unum discretion, so the court applied arbitrary-and-capricious review, which is very deferential to the administrator.

D. What Is “Substantial Evidence”?

In this ERISA context, “substantial evidence” means:

“such relevant evidence as a reasonable mind might accept as adequate to support a conclusion” — more than a mere trace of evidence, but less than a preponderance.

In practical terms:

The administrator’s decision does not have to be the best or only interpretation of the record.
Even where the evidence could support either upholding or reversing a benefit, the court must affirm if the administrator’s position is at least reasonable.

This is why the existence of conflicting medical opinions does not automatically make a denial arbitrary or capricious.

E. Structural Conflict of Interest

A “structural conflict of interest” exists when the entity deciding claims also pays benefits (as with Unum here). This creates an incentive to deny claims.

Under Supreme Court and Eleventh Circuit law:

Such a conflict is one factor in assessing whether a decision was arbitrary and capricious.
It does not compel reversal by itself.
The claimant should show some indication that the conflict affected the decision (e.g., inconsistent evaluations, selective evidence use, procedural irregularities).

In Eggleston, although a structural conflict was conceded, there was no evidence it affected Unum’s review, and the claimant did not pursue the issue on appeal. The court therefore treated it as irrelevant in practice.

VI. Conclusion

Eggleston v. Unum Life Insurance Co. of America is a classic example of how deference to plan administrators operates in ERISA disability litigation. While not published and therefore not binding precedent, it offers several important takeaways:

Deferential review dominates when plans grant discretionary authority.
Once arbitrary-and-capricious review applies, courts will uphold an administrator’s decision if supported by substantial evidence, even in the face of conflicting medical opinions.
No special weight is owed to treating physicians under ERISA.
Administrators may reasonably credit file reviewers and independent experts over treating doctors, particularly where objective evidence is benign.
Social media and real-world activities are fair game.
Online posts showing travel, business activity, and attendance at lengthy events can legitimately inform an assessment of functional capacity.
Conflict-of-interest arguments must be developed.
Simply invoking a structural conflict is not enough; claimants must show how it influenced the decision-making process.
Long-term benefit payment does not guarantee indefinite benefits.
Administrators can and do terminate long-standing claims where they reasonably conclude the claimant no longer meets the “any gainful occupation” standard.

In sum, Eggleston reinforces the need for claimants to maintain robust, objective, and consistent medical documentation—and to be mindful that their public activities will be scrutinized—while providing administrators with a clear example of how to structure and document a defensible termination decision under ERISA.