Armani v. Northwestern Mutual Life Insurance

District court, which upheld ERISA insurer’s determination that plaintiff could perform sedentary work and thus was not entitled to long-term disability benefits, erred by rejecting plaintiff’s proposed definition of sedentary work on the basis that it was drawn from the Social Security context. An employee who cannot sit for more than four hours in an eight-hour workday cannot perform sedentary work that requires sitting most of the time.

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