Bucks v. Reliance Standard Life Insur., Co., 2000 U.S. App. LEXIS 11456 (6^th Cir. May 12, 2000) (unpublished)-Reliance Standard appealed a summary judgment by the magistrate judge in favor of Bucks on his claim for long-term disability benefits for headaches and depression.  Reliance Standard stated there was insufficient objective medical evidence to show that Bucks was totally disabled and unable to perform his job as an executive engineer.  Although Bucks demonstrated that he had headaches and depression, Reliance Standard required evidence that, after years of work with these conditions, he had become disabled by them.

            This court found that Reliance Standard did not abuse its discretion in denying Bucks' claim, considering the lack of "objective evidence" of debilitating headaches and depression.  It was not improper to investigate whether there was a physical explanation for Bucks' headaches.  This court noted that "subjective complaints are easy to make but almost impossible to refute."  Yeager v. Reliance Standard Life Ins. Co. 88 F.3d 376, 382 (6^th Cir. 1996); 1996 FED App. 0199P (6^th Cir.).  The policy required Bucks to show medical proof as to when he became totally disabled. None of the Bucks' medical reports were specific enough in detail or to the period in question.  Although, Bucks had a good case, Reliance Standard's decision was not "irrational or without basis or reason."