In a significant win for ERISA long-term disability (LTD) claimants, the Eleventh Circuit Court of Appeals recently reversed Reliance Standard Life Insurance Company’s denial of LTD benefits based on a pre-existing condition exclusion. The November 21, 2025 published decision in Johnson v. Reliance Standard Life Insurance Company, No. 23-13443, 2025 WL 3251015, __ F. 4th __ (11th Cir. Nov. 21, 2025) provides important protection for individuals with rare or difficult-to-diagnose medical conditions who face benefit denials under their employer-sponsored long-term disability plans.
Understanding the Johnson LTD Case
Cheriese Johnson worked in human resources and obtained long-term disability insurance coverage through her employer in 2016. Within months of her coverage becoming effective, she became totally disabled due to scleroderma—a rare autoimmune disease that causes hardening and thickening of the skin and other tissues.
When Johnson filed her disability claim, Reliance Standard denied her benefits, arguing that scleroderma was a “pre-existing condition” under her policy. The insurance company pointed to medical visits Johnson had during the three-month lookback period before her coverage began, during which she was treated for various symptoms including fatigue, nausea, swelling, and joint pain.
The critical issue: Johnson’s doctors had diagnosed her with nearly a dozen conditions during that lookback period—including fibromyalgia, borderline lupus, and bronchitis—but no one suspected scleroderma. The disease wasn’t diagnosed until four months after the lookback period ended, following a lung biopsy.
The Insurance Company’s Overreach
Reliance Standard took an extremely broad interpretation of the policy’s pre-existing condition language. The company argued that because Johnson received treatment for symptoms that were “not inconsistent with” scleroderma, her condition was excludable—even though neither Johnson nor any of her doctors knew she had the disease or intended to treat it during the lookback period.
The Eleventh Circuit firmly rejected this interpretation as unreasonable. The majority explained that the policy’s language requires that a person receive medical treatment “for” a specific sickness during the lookback period. The word “for” connotes intent and purpose—and quoting then-Judge Alito in a prior opinion noted: “it is hard to see how a doctor can provide treatment ‘for’ a condition without knowing what that condition is or that it even exists.”
Why This Decision Matters for ERISA LTD Claimants
This ruling is particularly important for individuals with rare diseases or conditions that are difficult to diagnose. Under Reliance Standard’s rejected interpretation, virtually any prior medical treatment could be used to deny coverage for a later diagnosis, as the court noted: an insurance company could “deny coverage for a brain tumor if the doctor encouraged a patient with headaches to drink more water.”
The decision protects claimants from what the court called an “ex post facto analysis” where “a whole host of symptoms occurring before a ‘correct’ diagnosis is rendered, or even suspected, can presumably be tied to the condition once it has been diagnosed.” This backward-looking reinterpretation would render pre-existing condition exclusions so broad as to be virtually meaningless.
The Legal Framework: ERISA’s Six-Step Process
The Johnson decision also illustrates the often-criticized and complex framework that the Eleventh Circuit uses to review ERISA long-term disability claims. The court applies a six-step analysis when an insurance company denies benefits:
- Determine whether the denial was wrong under a “de novo” (fresh review) standard
- If wrong, determine whether the insurance company had discretion to interpret the plan
- If the company had discretion, determine whether reasonable grounds supported the denial
- If no reasonable grounds exist, reverse the denial
- Evaluate whether conflicts of interest exist
- Consider conflicts as a factor in determining whether the decision was arbitrary and capricious
In Johnson’s case, the court found that Reliance Standard’s decision was not only wrong but also unreasonable—meaning it failed at step three of this analysis. Even under the deferential “arbitrary and capricious” standard of review, the insurance company’s interpretation stretched the policy language “beyond what it can reasonably bear.”
What This Means for Your LTD Claim
If your LTD benefits have been denied based on a pre-existing condition exclusion, the Johnson decision may provide a strong basis for appeal, particularly if:
- You were treated for general symptoms rather than a specific diagnosed condition during the lookback period
- Your disabling condition is rare or was difficult to diagnose
- Your doctors did not suspect your ultimate diagnosis during the lookback period
- The insurance company is using hindsight to connect unrelated symptoms to your current condition
The Johnson ruling makes clear that ERISA does not permit insurance companies to use creative interpretations of policy language to deny legitimate claims. Treatment for symptoms does not automatically constitute treatment “for” an underlying condition that no one knew existed.
The Importance of Experienced ERISA LTD Representation
ERISA disability cases are highly technical and require specialized knowledge of both federal law and insurance industry practices. The Johnson decision demonstrates how insurance companies may take unreasonable positions when denying claims, hoping that claimants will simply give up or accept the denial without challenge.
At The Garner Firm, our attorneys have extensive experience handling ERISA long-term disability claims and appeals. We understand the tactics insurance companies use to avoid paying benefits, and we know how to build compelling cases that hold insurers accountable to the actual terms of their policies.
Our team has successfully represented countless clients in disability benefit disputes, helping them secure the benefits they need and deserve. We stay current on developing case law like the Johnson decision to ensure our clients benefit from the most recent legal precedents.
Take Action: Protect Your Rights
If you have been denied long-term disability benefits based on a pre-existing condition exclusion—or any other reason—time is critical. ERISA imposes strict deadlines for filing administrative appeals and lawsuits. Missing these deadlines can result in the permanent loss of your right to challenge the denial.
Don’t let an insurance company’s unreasonable interpretation of policy language prevent you from receiving the benefits you paid for and need. The Johnson decision shows that courts will reject overly broad denials when claimants have skilled legal representation to advocate for their rights.
Contact The Garner Firm today for a consultation about your ERISA disability claim. Our experienced ERISA lawyers will review your denial, explain your options, and help you develop a strategy to fight for your benefits. We work on a contingency fee basis for many ERISA cases, which means you pay no attorney’s fees unless we recover benefits for you.
Your health and financial security are too important to leave to chance. Let our knowledge and experience work for you in navigating the complex world of ERISA litigation. Reach out to The Garner Firm now to learn how we can help you challenge an unfair benefit denial and secure the long-term disability benefits you deserve.
The information provided in this blog post is for general informational purposes only and does not constitute legal advice. Every ERISA case is unique and depends on the specific facts and policy language involved. For advice about your particular situation, please contact an experienced ERISA lawyer.