Federal Court Upholds Denial of Disability Benefits
📌 In brief
The Federal Court of Appeal ruled that a claimant was not eligible for disability benefits under the Canada Pension Plan. The Court found that the claimant did not provide enough evidence to prove that she was disabled and unable to apply for these benefits herself.
⚖️ Legal holding
An individual must provide sufficient evidence to demonstrate both disability and incapacity to apply for disability benefits under the Canada Pension Plan.
📖 Technical summary
The Appeal Division's decision regarding the claimant's eligibility for disability benefits was upheld as reasonable.
📜 Headnote Official document
The Federal Court of Appeal upheld the denial of disability benefits to the claimant, finding that the Appeal Division's decision was reasonable and based on the evidence presented. The claimant argued that she met the eligibility criteria for disability benefits under the Canada Pension Plan, but the Court found that the evidence did not support her claims.
📚 Full judgment Official document
Date: 20260625 Docket: A-84-26 Citation: 2026 FCA 119 CORAM: GOYETTE J.A. HECKMAN J.A. PAMEL J.A. BETWEEN: [NAME] Applicant and ATTORNEY GENERAL OF CANADA Respondent Heard at Ottawa, Ontario, on June 25, 2026. Judgment delivered from the Bench at Ottawa, Ontario, on June 25, 2026.
REASONS FOR
JUDGMENT OF THE COURT BY: GOYETTE J.A. Date: 20260625 Docket: A-84-26 Citation: 2026 FCA 119 CORAM: GOYETTE J.A. HECKMAN J.A. PAMEL J.A. BETWEEN: [NAME] Applicant and ATTORNEY GENERAL OF CANADA Respondent
REASONS FOR
JUDGMENT OF THE COURT (Delivered from the Bench at Ottawa, Ontario, on June 25, 2026). GOYETTE J.A. [ 1 ] [NAME] receives a retirement pension under the Canada Pension Plan , R.S.C. 1985, c. C-8. The Minister of Employment and Social Development determined that she was not eligible for a disability pension or a post-retirement disability benefit. [NAME] appealed the denial to the Social Security Tribunal. Following a new hearing, the Appeal Division dismissed [NAME]’s appeal: 2025 SST 1353. [ 2 ] Among other things, the Appeal Division found that [NAME] had not demonstrated that she had been disabled or that she had been incapable of forming or expressing an intention to apply for a disability pension. [NAME] been disabled and incapable of forming an intention to apply, she would have been deemed to have applied for a disability pension before she started receiving retirement benefits and would therefore have been retroactively eligible for a disability pension as of when she became disabled: ss. 42(2), 44(1)(b), 60(8) to (10), 66.1(1.1), and 70(3). [ 3 ] In this Court, [NAME] seeks an order setting aside the Appeal Division’s decision and remitting the matter for reconsideration. She takes issue with the Appeal Division’s findings that she was not disabled or incapacitated. [ 4 ] On judicial review, this Court can only intervene if the Appeal Division’s reasons and conclusions are not reasonable: [NAME] v. Canada (Attorney General) , 2022 FCA 47 at para.7, citing Canada (Minister of Citizenship and Immigration) v. [NAME] , 2019 SCC 65 at paras. 83, 86, among other decisions; [NAME] v. Canada (Attorney General) , 2021 FCA 211 at para. 35, citing [NAME] v. Canada (Attorney General) , 2018 FCA 100 at para. 3. [ 5 ] We find that the Appeal Division’s reasons and conclusions are reasonable. They bear the hallmarks of reasonableness: justification, transparency and intelligibility: [NAME] at para. 99. [ 6 ] With respect to disability, the Appeal Division applied the definition of disability in subsection 42(2), which requires claimants to demonstrate that they suffer from a “severe” and “prolonged” disability that renders them “incapable regularly of pursuing any substantially gainful occupation.” The Appeal Division then reviewed the evidence and found that it did not establish disability under the Canada Pension Plan : Decision at paras. 14, 16–22. While it acknowledged [NAME]’s serious medical condition in 1997, the Appeal Division noted that her diagnosis could not be equated with a severe disability under the Canada Pension Plan : Decision at para. 19, citing [NAME] v. Canada (Minister of Social Development) , 2008 FCA 33. We find nothing unreasonable with such a finding given the record before the Appeal Division. [ 7 ] As for incapacity, the Appeal Division said that it was “beside the point” because, having failed to demonstrate that she was disabled, [NAME] could not claim a disability benefit. The Appeal Division nevertheless addressed incapacity. [ 8 ] The Appeal Division recognized that the test for incapacity is not the same as the one for disability: Decision at paras. 25–26; see also [NAME] v. Canada (Attorney General) , 2023 FCA 122 at para.
78. Relying on relevant statutory provisions and this Court’s jurisprudence, the Appeal Division said that the test asks whether a claimant has the mental capacity to form or express an intention to apply for disability benefits: Decision at paras. 27–32, citing subsections 60(8) and (10); Canada (Attorney General) v. [NAME] , 2008 FCA 78; [NAME] ; and [NAME], among other cases. [NAME] agrees that this is the applicable test, but she says it was misapplied. [ 9 ] [NAME] essentially argues that the Appeal Division failed to grapple with the evidence that she put before it. We disagree. Based on the record, we cannot conclude that, in reaching its conclusions, the Appeal Division misapprehended or failed to account for the evidence before it: [NAME] at para. 126. [ 10 ] We will therefore dismiss the application. Since the respondent does not ask for costs, none shall be awarded. " Nathalie Goyette " J.A. FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-84-26 STYLE OF CAUSE: [NAME] v. ATTORNEY GENERAL OF CANADA PLACE OF HEARING: OTTAWA, ONTARIO DATE OF HEARING: June 25, 2026
REASONS FOR
JUDGMENT OF THE COURT BY: GOYETTE J.A. HECKMAN J.A. PAMEL J.A. DELIVERED FROM THE BENCH BY: GOYETTE J.A. APPEARANCES : [NAME] For The Applicant ON HER [NAME] For The Respondent SOLICITORS OF RECORD : [NAME] of Canada For The Respondent
⚖️ What tends to weigh in cases like this
✅ Tends to be accepted
- The Appeal Division's reasons and conclusions are reasonable, bearing the hallmarks of reasonableness: justification, transparency and intelligibility.
- The Appeal Division applied the correct definition of disability under subsection 42(2) of the Canada Pension Plan, requiring a severe and prolonged disability that renders a claimant incapable regularly of pursuing any substantially gainful occupation.
- The Appeal Division's finding that the claimant's diagnosis could not be equated with a severe disability under the Canada Pension Plan was reasonable given the record.
- The Appeal Division correctly recognized that the test for incapacity is not the same as the test for disability, and that the test asks whether a claimant has the mental capacity to form or express an intention to apply for disability benefits.
- Based on the record, the Court could not conclude that the Appeal Division misapprehended or failed to account for the evidence before it.
❌ Tends to be rejected
- The claimant argued that the Appeal Division failed to grapple with the evidence she put before it, but the Court disagreed.
Patterns observed in similar cases in this collection — every case is unique.
❓ Frequently asked questions
What did this decision decide?
The Federal Court of Appeal upheld the denial of disability benefits to the claimant.
What was the dispute about?
The dispute was over whether the claimant met the eligibility criteria for disability benefits under the Canada Pension Plan.
How did the court decide, and why?
The court decided that the claimant was not eligible for disability benefits because she did not provide sufficient evidence to prove her disability and incapacity to apply for benefits.
Which laws or rules were applied?
The Canada Pension Plan, ss. 42(2), 44(1)(b), 60(8) to (10), 66.1(1.1), and 70(3) were applied.
What was the argument that mattered most?
The argument that mattered most was whether the claimant provided sufficient evidence to prove her disability and incapacity to apply for benefits.
Was the decision for or against the person who brought the case?
The decision was against the person who brought the case.
What does this mean for someone in a similar situation?
Someone in a similar situation should ensure they provide strong evidence to prove their disability and incapacity to apply for benefits.
What evidence or documents mattered?
The evidence and documents related to the claimant's medical condition and ability to pursue substantially gainful occupation mattered.