Reliance Standard Life Insurance Denied A Disabled Worker with Scleroderma

One Woman. Ten Wrong Diagnoses. Zero Dollars Paid.

Cheriese Johnson started getting sick in December 2015. She went to the doctor. Then she went again. And again. Over the following months, she racked up visits to a neurologist, a pulmonologist, a thoracic surgeon, and a rheumatologist. Her doctors gave her ten different diagnoses. Not one of them was correct.

In July 2016, still undiagnosed and still suffering, Johnson got a job at The William Carter Company, a major children’s clothing brand. She enrolled in the company’s long-term disability insurance plan, administered by Reliance Standard Life Insurance Company. That policy went into effect on October 12, 2016.

By January 26, 2017, just four months later, Johnson could no longer work. In February 2017, a lung biopsy finally revealed what had been destroying her body all along: scleroderma, a rare, chronic autoimmune disease in which normal tissue is replaced with dense, thick fibrous tissue. No doctor had suspected it. No doctor had treated her for it. No one even had it on their radar.

She Filed Her Claim. Reliance Standard Said No.

Eight months after her diagnosis, Johnson filed a long-term disability claim with Reliance Standard. The company denied it. Reliance Standard’s reasoning: Johnson had received medical treatment during the three-month “lookback period” before her policy started, and some of those symptoms were theoretically compatible with scleroderma. Under the policy’s “Pre-existing Conditions Limitation,” Reliance Standard said it owed her nothing.

Johnson appealed internally. Reliance Standard hired an endocrinologist, a hormone specialist, to review her file. Not a rheumatologist, the type of doctor who actually treats scleroderma. An endocrinologist. That specialist concluded the symptoms “support a reported diagnosis of scleroderma.” Reliance Standard used that opinion to uphold the denial.

Johnson then sued under the Employee Retirement Income Security Act (ERISA). The district court ruled against her. She appealed to the Eleventh Circuit. On November 21, 2025, a three-judge panel reversed the denial, finding Reliance Standard’s interpretation of the policy was wrong, and went beyond wrong to actively unreasonable.

The Non-Financial Ledger

Numbers and legal standards dominate the court record, but the document also reveals, in clinical bullet-point form, exactly what Cheriese Johnson’s body went through before anyone understood why. On September 30, 2016, a single appointment produced a list of complaints that reads less like a medical chart and more like a body in crisis: numbness, coldness, and pain in all four extremities; nausea and vomiting; forgetfulness and cognitive impairment; fatigue; inability to control her bowels; blurred vision; fever; dropping things frequently; headaches; decreased appetite; syncope; dizziness; generalized aching; swelling of the feet and hands; and a loss of motor skills. That is sixteen separate symptoms recorded at one visit. No single diagnosis explained them all. No single doctor had answers.

Johnson visited doctors repeatedly across the lookback period, August through October 2016, and received prescriptions for conditions including gastritis, helicobacter pylori, sleep apnea, and bronchitis. None of those prescriptions were for what was actually happening to her. She was prescribed Cyclobenzaprine, a muscle relaxant, and Zofran, an anti-nausea medication. These drugs were treating symptoms that were themselves symptoms of a deeper disease no one had identified yet. Johnson was not being treated for scleroderma. She was being failed by a medical system trying to patch individual leaks while the entire hull was cracking.

The disease she actually had, scleroderma, causes normal tissue to be replaced with dense, thick fibrous tissue. It is not a disease you can observe from the outside easily, especially in early stages presenting as generic fatigue and joint pain. Johnson’s own rheumatologist did not diagnose it. Her neurologist did not diagnose it. Her pulmonologist did not diagnose it. It took a lung biopsy, a surgical procedure in which a piece of her lung tissue was physically removed and examined, to finally produce the answer. She had been sick since at least December 2015. She did not get a name for her illness until February 2017, more than a year later.

Then, after enduring over a year of undiagnosed, escalating illness, after finally getting answers from a lung surgery, after becoming so ill she could not work at all, Johnson filed her disability claim. Reliance Standard’s response was to hire an endocrinologist, a specialist in hormones, to review the file of a patient whose illness is an inflammatory autoimmune disease treated by rheumatologists. That specialist provided the opinion Reliance Standard needed to uphold its denial. The company did not hire the type of doctor best suited to evaluate scleroderma. It hired the type of doctor whose opinion could be used to justify a decision it had apparently already made. Johnson then spent years in court fighting for benefits she had paid into and been promised, while living with a progressive, disabling, incurable disease.

The Brain Tumor Argument: How Reliance Standard Rewrote the English Language

The policy Johnson paid for defined a “Pre-Existing Condition” as any sickness “for which the Insured received medical Treatment, consultation, care or services, including diagnostic procedures, or took prescribed drugs or medicines” during the three-month lookback period. The entire legal battle turns on two letters: the word “for.” Johnson’s argument was simple. You cannot treat a condition you have never heard of. The court agreed.

Reliance Standard’s argument was the opposite. The company told the court its interpretation meant that if any symptom treated during the lookback period was “not inconsistent” with a later diagnosis, that was enough to deny the claim entirely. The appeals court translated this into plain English: under Reliance Standard’s view, a doctor telling a dehydrated patient to drink more water has technically “treated” that patient for an undiagnosed brain tumor, because headaches are a symptom of both dehydration and brain cancer. The company confirmed this interpretation at oral argument. The court called it out directly.

The court further noted that under Reliance Standard’s logic, “any time a policy holder seeks medical care of any kind during the look-back period, the ‘symptom’ that prompted him to seek the care could potentially be deemed a symptom of a pre-existing condition, as long as it was later deemed consistent with symptoms generally associated with the condition eventually diagnosed.” Put differently: Reliance Standard wanted a policy that could deny almost any claim, at any time, for any reason, by working backward from a diagnosis to justify the denial.

They Hired the Wrong Doctor on Purpose

When Johnson appealed internally, Reliance Standard had a choice about who to hire to review her medical file. Scleroderma is an inflammatory autoimmune disease. It is primarily treated by rheumatologists. Reliance Standard retained an endocrinologist, a specialist in hormones and glands, to evaluate whether her records supported a scleroderma denial. The court’s record shows this specialist concluded the “symptoms/findings do support a reported diagnosis of scleroderma.” Reliance Standard used that conclusion to uphold the denial. The company chose the reviewer. The reviewer delivered the outcome the company needed.

The court also noted a significant gap in Reliance Standard’s denial letters: the company never actually specified which of Johnson’s symptoms it was claiming were “theoretically consistent with scleroderma.” It simply denied the claim on those grounds without identifying the specific evidence it relied on. The court called this out in a footnote, noting that Johnson did not even dispute that “at least one” symptom was arguably consistent, but the company never bothered to say which one or why it was determinative.

Legal Receipts: What the Court Actually Said

Ruling The Eleventh Circuit’s majority opinion contains some of the most direct condemnations of an insurance company’s reasoning you will find in a federal appellate decision. These are direct quotes from the record.

“It is no exaggeration to say that under Reliance Standard’s view, a patient told to drink more water because her headache was likely caused by her dehydration has been treated for cancer if she turns out to have a brain tumor. And that is true even if dehydration really was the root cause of the headache.” Eleventh Circuit Majority Opinion, November 21, 2025

“We do not overstate the company’s view — Reliance Standard doubled down on it at oral argument.” Eleventh Circuit Majority Opinion, Footnote 3, November 21, 2025

“To bless ‘such backward-looking reinterpretation of symptoms to support claims denials would so greatly expand the definition of preexisting condition as to make that term meaningless: any prior symptom not inconsistent with the ultimate diagnosis would provide a basis for denial.'” Eleventh Circuit, quoting Lawson v. Fortis Insurance, citing then-Judge Alito

“Reliance Standard urges us to apply a different policy than the one it wrote, reading it as if it barred coverage for claims arising from conditions that may have originated or existed during the lookback period, not conditions that were treated during that period.” Eleventh Circuit Majority Opinion, November 21, 2025

“It warps the ‘plain and ordinary meaning’ of the policy language, converting a preexisting-condition exclusion into a preexisting-symptom exclusion.” Eleventh Circuit Majority Opinion, November 21, 2025

“None of the tests Johnson underwent during this process ‘ever linked the symptoms she was experiencing’ to scleroderma, so doctors had no suspicion that she might have it. And that means there could be no ‘intention’ on the part of Johnson’s doctors to treat her for scleroderma. None.” Eleventh Circuit Majority Opinion, citing McLeod v. Hartford, November 21, 2025

Societal Impact: This Is the System Working as Designed

Economic Inequality: The Lookback Period as a Wealth Trap

The three-month lookback period in Johnson’s policy exists, legally speaking, to prevent fraud. The dissenting judge argued this explicitly, writing that the exclusion “serves the purpose of protecting insurers from fraudulent applicants seeking coverage for known diseases.” But Johnson’s case had zero fraud. She did not know she had scleroderma. Her doctors did not know. No one suspected it. The anti-fraud mechanism was deployed against a genuinely sick woman who had done nothing wrong.

Long-term disability insurance tied to employment, the kind Johnson had through The William Carter Company, represents a specific type of economic trap for workers who get sick close to a coverage start date. Workers with inherited wealth or savings have options when they get sick. They can pay out of pocket, seek additional coverage, take time off without financial ruin. Workers who depend on employer-sponsored insurance have one shot at coverage and one set of rules. When those rules are interpreted as broadly as Reliance Standard attempted, the coverage is effectively worthless for anyone who was already experiencing health problems when they enrolled, which describes a large proportion of people with serious chronic illnesses.

The burden of proof under ERISA in this circuit also fell on Reliance Standard to prove the exclusion applied, not on Johnson to prove it did not. Reliance Standard carried that burden by hiring an endocrinologist to review a scleroderma file and using a vague conclusion to justify a denial. The legal architecture was designed to protect workers. The company used it to deny one.

Public Health: Scleroderma, Rare Disease, and the Diagnosis Gap

Scleroderma affects an estimated 300,000 people in the United States. It disproportionately affects women, and particularly affects Black women, who develop more severe forms of the disease at higher rates than other demographic groups. The court record describes Johnson’s disease as “a rare, chronic autoimmune disease in which normal tissue is replaced with dense, thick fibrous tissue,” causing “joint pain and stiffness, persistent cough, shortness of breath, digestive and gastrointestinal problems, and fatigue.” These symptoms overlap substantially with dozens of other conditions, which is precisely why Johnson received ten wrong diagnoses over more than a year.

The diagnosis gap for rare autoimmune diseases is well documented. Patients often wait years between first symptoms and accurate diagnosis, cycling through specialists who treat individual symptoms without identifying the underlying cause. Johnson’s case illustrates this perfectly: she saw a neurologist, a pulmonologist, a thoracic surgeon, and a rheumatologist, all before anyone identified scleroderma. She received prescriptions for conditions she did not primarily have, drugs that treated surface symptoms while the core disease progressed. The insurance company then used that diagnostic journey, that period of medical uncertainty and systemic failure, as the basis to deny her every dollar of the coverage she paid for.

When insurance companies adopt interpretations that treat a patient’s good-faith attempts to get a diagnosis as evidence of a preexisting condition, they create a direct public health incentive to avoid doctors. A patient who suspects they might be sick, and who knows their insurance lookback period is active, now has a financial reason to delay seeking care until after that window closes. Reliance Standard’s interpretation, had it been upheld, would have encoded that incentive into federal insurance law.

Economic Inequality: The ERISA Labyrinth as Corporate Shield

ERISA, the federal law that governs employer-sponsored benefit plans, was enacted in 1974 to “promote the interests of employees and their beneficiaries in employee benefit plans, and to protect contractually defined benefits.” The court quotes this directly from Supreme Court precedent. In practice, ERISA has become one of the most effective corporate shields in American employment law. It preempts state insurance regulations, forces claimants into federal court with limited remedies, and creates a deferential standard of review that, as this court acknowledges, requires a decision to be upheld even “if there is evidence that would support a contrary decision,” as long as some reasonable basis exists for the denial.

The Eleventh Circuit’s own six-step review framework is acknowledged by the majority opinion itself to be “likely unnecessarily complex and may even obscure the lawful result in certain cases.” The court applies it anyway because it is binding precedent. Johnson had to navigate this framework alone through the administrative appeals process, then through the district court, which granted summary judgment to Reliance Standard, and then through the full appeals process. Only at the appellate level did she win, years into her illness, years after becoming disabled. The system was technically correct. But it was not fast, cheap, or accessible.

The “Cost of a Life” Metric