Client v. Metropolitan Life Insurance Co.
The court awarded our client long-term disability benefits due to multiple conditions, including fibromyalgia and depression, and later, the court ordered MetLife to retroactively reinstate various additional benefits and pay our client pre-judgment interest.
Our client worked as a senior auditor until she became disabled from fibromyalgia, chronic pain, and other conditions, including depression. She filed a claim for disability benefits under the plan that was provided by her employer and administered by MetLife.
MetLife approved our client’s claim for short-term disability benefits but later denied her requests for long-term disability benefits. This, we argued, was arbitrary and capricious, because our client had documentation from six treating doctors supporting the presence of disabling symptoms stemming from her fibromyalgia and depression, among other conditions.
The court agreed with us that MetLife’s decision was arbitrary and capricious. First, the court noted that “all of MetLife’s denials were based on a lack of objective evidence of disability,” yet MetLife chose to rely on doctors who formed their opinions about our client’s disabilities without an in-person examination instead of relying on our client’s treating physicians. Furthermore, MetLife did not use its right under the plan to select a doctor to examine our client physically. It made little sense for MetLife to claim there was insufficient evidence of our client’s disability, but at the same time, fail to pursue methods of obtaining more objective, physical evidence that were available to it.
Next, the court noted that one of our client’s main disabilities – fibromyalgia – is uniquely difficult to measure objectively. The Sixth Circuit has affirmed this fact multiple times in previous cases and in those cases, it addressed problematic actions that a plan administrator should avoid when assessing fibromyalgia. For example, it is more likely that a plan administrator’s decision is arbitrary and capricious when it chooses not to account for the effects of medications on a person’s disability status or chooses not to conduct an in-person examination, especially if the plan administrator is also making credibility determinations regarding an individual’s subjective complaints of pain. MetLife made all of those errors.
Therefore, the court concluded that our client was “totally disabled as defined by the Plan and that MetLife’s conclusion that [our client was] not disabled was arbitrary and capricious.” As a result, our client was entitled to benefits.
After helping our client win her ERISA long-term disability benefits, we filed motions seeking retroactive payment of our client’s long-term disability payments, an order of collateral benefits listed in the plan, and additional damages resulting from MetLife’s arbitrary and capricious denial of our client’s disability benefits. The court granted our requests.
First, the court noted that when a plan administrator engages in an arbitrary and capricious review of the medical record, the insured individual should receive retroactive benefits without a remand. MetLife’s review of our client’s claim was, in fact arbitrary and capricious, so the court rejected MetLife’s request for a remand and awarded our client retroactive benefits. The court concluded that MetLife “erred in denying [our client’s] claim, and [MetLife] should bear the burden of that error.”
Next, the court recognized that MetLife’s denial of our client’s claim caused her to lose various “collateral benefits.” For example, had she been properly found disabled, she would have been entitled to continued health insurance premiums through her employer; instead she had to pay for her health insurance. She also had to pay life insurance premiums after her disability and accept a reduction in her life insurance policy amount from $210,000 to $140,000.
Because she would have had that insurance coverage if MetLife had found her disabled, the court agreed with us that our client was entitled to reimbursements of these amounts as well as the option to reinstate her original pension retirement eligibility by repaying the early retirement pension payments she had received.
MetLife attempted to argue that these benefits were consequential damages, for which ERISA does not allow recovery, but the court rejected that argument, finding that our client was entitled to the benefits directly under the plan. Again, the court asserted that our client “should not be denied any benefits available under the Plan because of [MetLife’s] error.”
Finally, we successfully fought for pre-judgment interest for our client. She was forced to go without the disability payments she was entitled to during the litigation process. As such, the court found it appropriate to award pre-judgment interest on the payments our client should have received.