Megan King worked as a Senior Care Specialist for Medtronic until August 2018, when she was diagnosed with acromegaly after doctors discovered a pituitary adenoma growing on her brain. She underwent a pituitary hypophysectomy, and while the surgery successfully removed the tumor, King went on to develop chronic fatigue, cognitive dysfunction, and frequent headaches. She also developed panhypopituitarism, adrenal insufficiency, and multiple hormonal deficits. Reliance Standard Life Insurance Company, which provided disability coverage to Medtronic employees, approved her long-term disability claim in February 2019.
The dispute crystallized in August 2022, when Reliance determined that updated records showed no residual or recurrent pituitary adenoma and therefore no impairing physical condition. Reliance simultaneously found that evidence supported impairment from major depression and anxiety disorder, and informed King that her benefits would continue for twelve more months under the policy's mental-disorder provision — and then stop. King appealed, arguing her disabling symptoms were physically caused. Reliance failed to decide that appeal within the 45-day period required by Department of Labor ERISA claims procedure regulations, and Reliance has acknowledged the appeal was not timely decided. That failure triggered de novo review: because there was no valid exercise of discretion to defer to, Judge Gretchen S. Lund of the Northern District of Indiana reviewed the record independently.
The central question was not whether King is disabled — both sides agreed she is — but whether her cognitive impairment and chronic fatigue were caused by her physical conditions during the period from August 17, 2022 through September 14, 2023, the date the administrative record closed. King had already received the aggregate lifetime maximum benefit payments for a mental or nervous disorder under the policy.
Judge Lund found the evidence insufficient to establish physical causation. Treatment notes from King's primary care physician, Dr. Jakacki, documented significant hormonal deficits but categorized her memory and cognitive symptoms under psychiatric headings, describing her as anxious, easily overwhelmed, and experiencing cognitive slowing. Notes from her treating psychologist, Dr. Lombard, never referenced King's hormonal deficits at all. The court found that the treating doctors' March 2023 medical opinion forms — which concluded King's limitations stemmed from a neurocognitive disorder due to a medical condition rather than a mental condition — were unpersuasive because they were inconsistent with the doctors' own treatment records and lacked adequate substantive rationale.
The 2020 Social Security Administration disability determination did not help King's position. The court noted that the ALJ's decision expressly stated that, given disability was established when considering mental impairment alone, it was unnecessary to assess physical function. A vocational evaluation completed in May 2023 concluded King could not perform any occupation, but the court found that conclusion beside the point: the dispute was about causation, not the existence of disability.
Judge Lund denied King's motion for summary judgment and granted Reliance's motion for judgment on the administrative record, directing the clerk to enter judgment in favor of Reliance. The court was careful to note that its ruling is not a finding that King is not disabled.