ERISA-Seventh Circuit Overturns A Plan Administrator's Benefit Denial, Since The Plan Administrator Ignored Important Evidence Submitted By The Participant
In Majeski v. Metropolitan Life Insurance Co., No. 09-1930 (7th Cir. 2009), the plaintiff, Kirsten Majeski, had been employed by Metropolitan Life Insurance Company ("MetLife"), and had participated in MetLife's Short Term Disability Plan (the "Plan"). The case centers on the decision of MetLife, as plan administrator, to reject Majeski's claim for short-term disability benefits, after determining that Majeski had failed to submit enough evidence to support her claim. The district court had likewise rejected Majeski's claim for the benefits and had granted summary judgment against her.
The Court applied a deferential review to Metlife's decision to deny Majeski's claim for benefits, since the Plan granted discretionary authority to Metlife, as plan administrator, to determine a participant's entitlement to benefits. However, the Court found it troubling that one doctor's report--the sole basis for MetLife's decision to deny the claim--concludes, erroneously, that Majeski did not submit objective evidence of functional limitations that were the source of her disability. This doctor did not acknowledge or analyze the significant evidence that Majeski did offer on that matter. The Court felt that these omissions made Metlife's claim denial arbitrary and capricious, and said that a plan administrator's claims procedure is not reasonable if the plan administrator's determination of a benefit claim ignores, without explanation, substantial evidence that the plaintiff submitted on the central issue-here, Majeski's functional limitations.
Based on the foregoing, the Court overturned Metlife's benefit claim denial and the district court's summary judgment against the plaintiff. The Court remanded the case back to the district court, which would turn the case over to Metlife to again review the plaintiff's claim for short-term disability benefits, but this time taking into account the evidence she offered.