Facts

Dr. Caroline L. Conor was a practicing physician. She was entitled to and received partial disability benefits through an individual disability insurance policy issued by The Paul Revere Life Insurance Company. In addition, she was insured under an ERISA-governed group long-term disability policy offered by her employer and insured by Unum Life Insurance Company of America. Dr. Connor applied for long-term disability benefits under the ERISA plan, but her claim was denied, so she filed a lawsuit against Unum.

PLAINTIFF'S CONTENTIONS: Dr. Connor contended that Unum's decision to deny her disability claim was incorrect. Unum's claim decision was based on the assertion that Dr. Connor was not a "full time employee" prior to her disability. Dr. Connor argued that the policy did not state that only employees officially classified by the employer as "full time" were eligible for benefits; rather it stated that any employee who works "at least 30 hours per week" is considered to be in "Active Employment" and therefore eligible for Plan benefits. Dr. Connor contended that she met this requirement and is disabled, and was therefore entitled to LTD benefits.

DEFENDANT'S CONTENTIONS: Unum did not dispute that Dr. Connor's physical condition rendered her unable to continue to perform her duties as a physician for her employer. Rather, Unum contended that Dr. Connor was not eligible to receive long-term disability benefits under the plan because her employer referred to her as a "part-time employee" and she did not provide sufficient evidence to show she worked enough hours to qualify as a full time employee under the plan.

Result

The court noted that while the plan explicitly excluded seasonal and part time workers from coverage, it did not require require that an employee be classified as "full-time" by the employer to be eligible for benefits under the Plan. Rather, it only required that the employee meet the Plan's definition for "Active Employment," defined as any employee who works "at least 30 hours per week." The court determined that through a declaration signed under penalty of perjury and a schedule of work and on-call hours, Dr. Connor provided sufficient evidence that she worked at least 30 hours a week and therefore satisfied the plan's requirement for disability benefits.