Nichols v. Verizon Communications Inc., 78 Fed.Appx. 209 (3^rd Cir. 2003) Employee sued employer under ERISA. U.S. District Court of New Jersey Jerome Sim granted summary judgment for defendant. Plaintiff appealed. Court of Appeals Judge Nygaard affirmed. The Court held that plaintiff’s claim of CFS, chronic fatigue syndrome. must be supported by existence of objective tests that showed evidence of her symptoms and that since there was no such adequate evidence a reasonable person could deny benefits.