The U.S. Court of Appeals for the Eleventh Circuit has affirmed a lower court's grant of summary judgment to ReliaStar Life Insurance Company, denying disability benefits to a surgeon who developed a career-ending tremor. The decision in *Alyosha S. Tunkle v. ReliaStar Life Insurance Company* (11th Cir. 2026) highlights the complex intersection of ERISA disability claims and preexisting condition exclusions in employer-sponsored insurance plans.
Dr. Alyosha Tunkle worked as a general surgeon for 21st Century Oncology, Inc., when he developed a disabling tremor that effectively ended his surgical career. His employer maintained group long-term disability insurance through ReliaStar Life Insurance Company, which covered employees working 30 or more hours per week. However, the policy contained an exclusion for preexisting conditions, a provision that became central to the litigation.
The case turned on a critical timing issue: whether Dr. Tunkle had temporarily lost his insurance coverage before he consulted a doctor about his disabling tremor. According to the court's per curiam opinion, the insurance company's administrator concluded that Dr. Tunkle's disability was caused by a preexisting condition, making him ineligible for benefits under the policy's exclusionary language.
ERISA disability cases often involve complex medical evidence and require courts to determine whether plan administrators acted reasonably when denying claims. The Employee Retirement Income Security Act of 1974 governs most employer-sponsored benefit plans and establishes specific standards for reviewing benefit denials. Under ERISA, courts typically defer to plan administrators' decisions unless they lack a reasonable basis or constitute an abuse of discretion.
The Eleventh Circuit's analysis focused on whether the administrative record reasonably supported the conclusion that Dr. Tunkle's tremor constituted a preexisting condition. The court examined contemporaneous employment records to determine the timeline of Dr. Tunkle's coverage and medical consultations. This factual inquiry proved decisive in upholding the insurance company's denial.
Preexisting condition exclusions are common features in disability insurance policies, designed to prevent individuals from obtaining coverage after they become aware of potential disabilities. These provisions typically define preexisting conditions as health issues for which medical advice, treatment, or care was received within a specified period before coverage began or was reinstated.
For medical professionals like Dr. Tunkle, disability insurance represents particularly high stakes. Surgeons and other specialists often carry substantial disability coverage because their highly specialized skills cannot easily transfer to other occupations if they become unable to perform their specific duties. The loss of surgical capability due to tremors, vision problems, or other physical impairments can effectively end a surgeon's career, making disability benefits crucial for financial security.
The case illustrates ongoing tensions between medical professionals and disability insurers over coverage interpretations. Insurance companies face pressure to control costs and prevent fraudulent claims, while physicians argue that legitimate disabilities should be covered regardless of technical policy interpretations. These disputes often involve detailed medical evidence and require courts to balance competing interests under ERISA's framework.
The Middle District of Florida originally granted summary judgment to ReliaStar, finding that the insurance company's decision had a reasonable basis in the administrative record. Summary judgment is appropriate when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law. In ERISA cases, this standard typically requires showing that the plan administrator's decision was not arbitrary or capricious.
The Eleventh Circuit's affirmance suggests that the contemporaneous employment records provided sufficient support for the preexisting condition determination. The court's per curiam opinion indicates that the panel found no abuse of discretion in the administrator's interpretation of the policy terms and application to Dr. Tunkle's circumstances.
This decision joins a substantial body of federal case law addressing ERISA disability claims and preexisting condition exclusions. Courts across the country regularly grapple with similar issues as employees challenge insurance company denials of disability benefits. The outcomes often depend heavily on the specific policy language, medical evidence, and timing of coverage and medical consultations.
The case also reflects broader healthcare industry challenges as medical professionals navigate complex insurance arrangements while managing their own health issues. For practicing physicians, the intersection of professional responsibilities and personal health concerns creates unique pressures that traditional employment disability frameworks may not adequately address.
Dr. Tunkle's unsuccessful appeal underscores the importance of understanding policy terms and maintaining continuous coverage when dealing with potential health issues. The decision serves as a reminder that even highly educated professionals can face significant challenges when navigating ERISA benefit denials and the federal court system's deferential review standards.