Willow Rorabaugh worked as a Branch Office Administrator, a position requiring sustained sitting, frequent hand use, bending, twisting, and postural tolerance. She underwent back surgery for spinal stenosis in April 2003 and initially received short-term disability benefits.
Her recovery was complicated by progressive neurological symptoms, including gait disturbance, rigidity, fatigue, and tremors. Neurology evaluations resulted in a Parkinson’s disease diagnosis. Treating physicians concluded she could not return to work. The insurer relied on internal duration guidelines and generalized “sedentary work” assumptions rather than evaluating her actual occupational duties and failed to properly transition the claim to long-term disability.
After a bench trial under de novo review, the district court found Rorabaugh totally disabled under the plan and awarded benefits. The Ninth Circuit affirmed, rejecting disability determinations based on abstract sedentary-work concepts divorced from real job demands.
