District Court Clarifies That “Disability” Requiring Workplace Accommodation Does Not Entitle Plaintiff to Disability Benefits

In Cannon v. Charter Commc’ns Short Term Disability Plan, No. 3:18-CV-041-DCK, 2019 WL 235325 (W.D.N.C. Jan. 16, 2019), the Plaintiff sought benefits under his employer’s self-insured short-term disability plan (the “Plan”), claiming he was unable to work due to recurrent vertigo, sleep apnea, heart disease, insomnia, and other, related conditions. In support of his claim, he submitted documentation from his sole treating physician, which stated he was unable to perform the essential functions of his position, but identified his only restriction as an inability to “drive in traffic.” To be eligible for benefits under the Plan, Plaintiff needed to demonstrate that he was unable to perform the essential duties of his occupation.

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