Trial Testimony for Long Term Disability Cases

LTD trial testimony, where applicable, addresses the policy definition, transferable skills findings, and labor market viability for any identified suitable occupations.

Checklist

  1. Review the administrative record references
  2. Prepare policy-definition explanation for the jury or bench
  3. Rehearse TSA and LMS presentation
  4. Prepare on functional capacity application

Questions to ask the expert

  • What does the policy definition require?
  • What occupations meet the policy criteria?
  • How did you apply the functional capacity evaluation?

Timeline

1 day-of-trial prep session.

Required documents

  • Policy
  • TSA and LMS
  • FCE
  • Administrative record

Common pitfalls

  • Straying beyond the administrative record
  • Confusing own-occupation and any-occupation

Frequently Asked Questions

Do LTD cases typically go to jury?

Most ERISA LTD cases are bench trials or summary judgment; non-ERISA policies may reach jury.

References

  1. U.S. DOL ERISAGovernment

Ready to Get Started on long term disability cases?

Contact KWVRS to discuss scope, timing, and the deliverables appropriate to the matter. Plaintiff and defense.