Satterwhite v. Metropolitan Life Insurance Company
No. 1:06-CV-165, 2011 WL 1103429 (E.D. Tenn. Feb. 19, 2011) (Not reported in F. Supp. 2d)
Our client, Ms. Satterwhite, had to stop working at U.S. Enrichment Corporation’s (USEC) Paducah Gaseous Diffusion Plant as a Health Physics Technician in October 2001 due to major depression and anxiety. Satterwhite v. Metro. Life Ins. Co., 2011 WL 1103429 at *1. The plant was the only place in the United States that enriched uranium, and the Paducah Gaseous Diffusion Plant was one of the top five targets in the September 11, 2001 terrorist attacks. Satterwhite v. Metro. Life Ins. Co., 2011 WL 1103429 at *4.
On June 24, 2002, MetLife awarded Ms. Satterwhite long-term disability benefits. Satterwhite v. Metro. Life Ins. Co., 2011 WL 1103429 at *1. As required by the plan, Ms. Satterwhite pursued a claim of disability with the Social Security Administration (SSA) and was awarded total disability by the SSA in early 2003. Id. Then, in April 2004, MetLife awarded her phase two benefits — those awarded if a claimant is unable to perform any job. Id. On October 4, 2005, Ms. Satterwhite was notified that MetLife was terminating her benefits effective August 31, 2005. Id. Ms. Satterwhite appealed the denial of her benefits directly to MetLife, and they issued her two denial letters, the last one on December 20, 2005. Id. After that, we helped Ms. Satterwhite file an ERISA complaint in district court for wrongful denial of benefits, and, in 2007, the court remanded the case back to MetLife for a full and fair review. Id. On remand, MetLife denied Ms. Satterwhite her disability benefits, and, in 2011, we helped her bring this second ERISA action following the termination of her disability benefits. Id.
The court noted that “the problems which the District Court found pervaded MetLife’s decision [to deny Ms. Satterwhite’s disability benefits] prior to remand continue to pervade MetLife’s decision after remand.” Satterwhite v. Metro. Life Ins. Co., 2011 WL 1103429 at *9. The plan required that “in order to receive continuing benefits, [she] must furnish periodic medical evidence of [her] illness or injury if requested by the Company.” Satterwhite v. Metro. Life Ins. Co., 2011 WL 1103429 at *8 (emphasis added). It was not up to Ms. Satterwhite to provide MetLife with specific medical tests or information unless requested to do so. Satterwhite v. Metro. Life Ins. Co., 2011 WL 1103429 at *11. Even after remand, MetLife continued to blame Ms. Satterwhite for not providing information to them that, they said, would provide evidence of her condition. Id.
Shortly after MetLife’s original termination of her benefits, the plaintiff moved with her family from Kentucky to Tennessee and changed her mental health provider from Dr. Meyer to Dr. Tim Larson with Behavioral Health Associates. Satterwhite v. Metro. Life Ins. Co., 2011 WL 1103429 at *2. She also went to Kathy Scott, a certified clinical social worker, at the suggestion of Dr. Larson. Satterwhite v. Metro. Life Ins. Co., 2011 WL 1103429 at *4. The purpose of this therapy was to address anxiety and stress. Id. Ms. Satterwhite also saw Dr. Sandra Kilpatrick, a licensed clinical psychologist, who diagnosed Ms. Satterwhite with Major Depressive Disorder, Generalized Anxiety Disorder, Panic Disorder with Agoraphobia, Obsessive-Compulsive Disorder, and Post-Traumatic Stress Disorder. Id. at 5. When Dr. Kilpatrick met with Ms. Satterwhite, the psychologist opined that “[g]iven the severity of her depression, her anxiety, and the agoraphobia, it is not likely that her ability to sustain consistent work will change in the foreseeable future.” Satterwhite v. Metro. Life Ins. Co., 2011 WL 1103429 at *5.
The court agreed with us and found in favor of the plaintiff. The court found that MetLife’s decision to deny her long-term disability benefits was indeed arbitrary and capricious. Satterwhite v. Metro. Life Ins. Co., 2011 WL 1103429 at *11. The court noted that MetLife continued to fault Ms. Satterwhite for not providing objective evidence and specific types of tests when objective evidence was not usually available for Ms. Satterwhite’s type of illness. Id. Before stating that MetLife’s decision to terminate Ms. Satterwhite’s benefits should be reversed and that her disability benefits under the plan should be awarded, the court observed that MetLife could not go back in time and perform tests on the plaintiff, and any further testing would not be of value. Id.