A Texas woman has filed a disability insurance lawsuit against Unum Life Insurance Company of America, claiming they improperly denied her claim for disability benefits.

Plaintiff Sharon E. is a former employee of Baylor College of Medicine, where she worked as a physician billing assistant. As a Baylor employee, Sharon was covered by Baylor’s long-term disability insurance plan administered by defendant Unum Life Insurance Company of America. In November 2010, Sharon’s disabilities caused her to end her employment with Baylor. She filed a claim with Unum for long-term disability benefits in March 2011, but Unum denied that claim in May 2013, according to the disability insurance lawsuit.

Sharon says she has a few different disabilities that prevent her from working. A prior fall left her with a broken tailbone and three broken discs in her spine. She also has mental illnesses diagnosed as bipolar disorder, depression, and anxiety, and she suffers from weekly migraine headaches. In disability benefits parlance, her conditions are classified as both exertional, meaning they impair her ability to meet the strength demands of her former job, and nonexertional, meaning they inhibit her ability to meet job requirements not related to strength.

Following Unum’s initial denial, Sharon submitted additional medical documentation of her disabilities and asked Unum to administratively review her claim. In March 2014, Unum affirmed its original denial, based solely on a review of Sharon’s paper records and without conducting any new exam. With the affirmation, Unum gave Sharon notice that she had exhausted her administrative remedies. Sharon then filed her current disability insurance lawsuit.

Contrary to Unum’s determination, Sharon argues that she is disabled in terms of Unum’s disability compensation plan and is therefore entitled to disability benefits. She states that her treating physicians can confirm her conditions “have resulted in restrictions in activity, have severely limited Plaintiff’s range of motion, and have significantly curtailed her ability to engage in any form of exertional activity.” She alleges these disabilities prevent her from maintaining the “pace, persistence and concentration” required for full-time employment.

Parallel to her Unum claim, Sharon also applied for and received a determination of “total disability” from the Social Security Administration, or SSA. Sharon now argues that the SSA’s determination of total disability should preclude any contrary determination by Unum because the standard the SSA applies to determine disability (unable to perform “any occupation in the National Economy”) is more restrictive that that applied by Unum (unable to perform “Any Occupation”).

Sharon alleges Unum has an internal conflict of interest because the money that is the subject of Unum’s disability decisions comes from Unum’s own funds. She also states that Unum’s plan entitled her to an exam at the appeal level, which would have given her reviewers more information than her medical file alone.

In terms of legal claims, Sharon groups three arguments together as a single cause of action under the federal Employee Retirement Income Security Act, or ERISA. She claims Unum failed to properly weigh the evidence of her disability, wrongly interpreted the definition of “disability” in the policy, and violated a contractual obligation to furnish her with disability benefits.

The Disability Insurance Lawsuit is Case No. 4:15-cv-1012, in the U.S. District Court for the Southern District of Texas.