Legal Summary: Keegan v. Metropolitan Life Insurance Company
Keegan v. Metropolitan Life Insurance Company
Not Reported in F. Supp. 3d (2014)
Our client worked as a senior engineer for a technology company, which was a demanding position requiring him to manage, install, and maintain high-end computer systems and be “on call 24 hours/day.” He was diagnosed with severe cancer, leading him to undergo chemotherapy treatments. He was later evaluated in a neuropsychological exam, after which the examining physician opined that he was “unlikely” to “resume competitive employment at this time” due to cognitive weaknesses.
He applied for and received the maximum amount of short-term disability benefits from Metropolitan Life Insurance Company before transitioning his claim to long-term disability benefits. MetLife initially approved these benefits, but later found that our client had improved to the point that he was no longer disabled under the terms of the plan.
The denial stated that there “was a question of some difficulty with his cognitive functioning,” but “the [consultant] noted there was nothing in the record that would suggest that [our client] had any specific difficulty” with cognitive functioning. Our client filed an appeal. During the appeal, MetLife hired two outside consultants to review the records, but at no point did MetLife ask for him to undergo an in-person exam. MetLife denied the claim on appeal.
We brought suit, arguing that MetLife’s decision to deny our client’s claim was arbitrary and capricious due to a lack of evidence showing that his condition had improved since he was initially deemed disabled under MetLife’s plan.
The court used the arbitrary and capricious standard of review when examining MetLife’s denial of benefits because MetLife’s plan grants the administrator discretionary authority to determine eligibility for benefits or construe terms of the plan. Marks v. Newcourt Credit Group, Inc., 342 F.3d 444, 456 (6th Cir.2003.) The court examined MetLife’s decision to determine whether its decision was “rational in light of the plan’s provisions.”
Our client agreed that his psychiatric symptoms had improved, but that he maintained “cognitive deficiencies” which were distinct and had not improved at the time of MetLife’s discontinuation of benefits.
Despite MetLife arguing otherwise, the Court determined that our client’s psychiatric symptoms were distinct from his cognitive symptoms, and that an improvement in the former did not mean that his cognitive deficiencies had improved to the point he was no longer disabled under MetLife’s plan.
Without evidence that our client’s cognitive deficiencies had improved, the only evidence in the record of cognitive impairments was a finding by a physician who determined that our client was disabled due to his cognitive symptoms and that “it appear[ed] unlikely that he would be able to resume competitive employment at this time.”
The Court concluded that MetLife’s discontinuation of benefits was not based on a rational basis as the evidence in the record does not support the conclusion that our client’s cognitive impairments had improved to the point that he was no longer disabled. The court ruled that our client should be awarded retroactive benefits for the 22-month period in which he was entitled to benefits because he had not shown improvement that would consider him no longer disabled under the plan. He was also awarded ongoing benefits going forward so long as he remained disabled under the plan
