Sparks v. Unum Life Insur. Co., 2000 U.S. App. LEXIS 18169 (6^th Cir. Jul. 21, 2000)(Unpublished)-Plan language requiring that a claimant show "proof" of disability (rather than "satisfactory proof," or "some other qualitative threshold of proof") does not grant discretion in a plan administrator. Thus, ERISA did not require deferential review under the arbitrary and capricious standard. This court found that Sparks' medical evidence showed that she was entitled to long-term disability benefits. However, she was not entitled to a waiver of premiums under the policy, since she failed to present sufficient evidence that in addition to being unable to work as a housekeeper, she could not perform "any" gainful work for which she was reasonably fitted.