ERISA-Eighth Circuit Court Of  Appeals Upholds The District Court’s Grant Of Summary Judgment To Metlife On Its Decision To Deny Long Term Disability Benefits  

In Cooper v. Metropolitan Life Insurance Company, No. 16-3429 (8th Cir. 2017), Michelle Cooper  (“Cooper”) had brought this action pursuant to ERISA section 502(a)(1)(B), claiming that Metropolitan Life Insurance Company (“MetLife”) improperly denied her long term disability (“LTD”) benefits under a group insurance plan sponsored by her former employer, Anheuser-Busch Companies, LLC (“Anheuser-Busch”). The district court entered summary judgment in favor of MetLife, finding that there was no abuse of discretion. Cooper now appeals from that decision, arguing that the court erred in applying an abuse of discretion standard of review to MetLife’s decision, and that it improperly excluded two physician’s affidavits from the record. Alternatively, Cooper contends that MetLife abused its discretion in denying LTD benefits.

Upon reviewing the case, the Eighth Circuit Court of Appeals (the “Court”) found no error by the district court. The Court said that Cooper presented no evidence of a  conflict of interest, or other indicia of biased decision making, by MetLife. Further, found the Court, the district court did not err by excluding the two affidavits from the record. Finally, the Court found that MetLife did not abuse its discretion by denying LTD benefits to Cooper where MetLife properly considered all medical records, APS reports, comments, and other information submitted by Cooper and her physicians.  Accordingly, the Court affirmed the district court’s summary judgment.

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