ERISA-Sixth Circuit Upholds Insurer/Administrator’s Decision To Deny LTD Benefits

In Judge v. Metropolitan Life Insurance Company, No. 12-1092 (6th Cir. 2013), the plaintiff, Thomas Judge (“Judge”), was appealing a decision by the district court on the administrative record in favor of the defendant, Metropolitan Life Insurance Company (“MetLife”), who had denied Judge long-term disability (“LTD”) benefits.

In this case, Judge had undergone surgery to repair an aortic valve and a dilated ascending aorta, and had applied for LTD benefits under a group insurance policy (the “Plan”) issued and administered by MetLife. MetLife denied the LTD benefits, however, when it determined that Judge was not totally and permanently disabled under the terms of the Plan. After exhausting MetLife’s internal administrative procedures, Judge brought suit under ERISA to recover the LTD benefits.

Judge argued on appeal that MetLife’s denial of LTD benefits was arbitrary and capricious. Specifically, he contended that: (1) MetLife applied the wrong definition of “total disability” to Judge’s claim, (2) MetLife erred in failing to obtain vocational evidence before concluding that Judge was not totally and permanently disabled, (3) MetLife erred in conducting a file review by a nurse in lieu of having Judge undergo an independent medical examination, and (4) there was a conflict of interest because MetLife both evaluates claims and pays benefits under the Plan. However, the Sixth Circuit Court of Appeals (the “Court”) disagreed with these contentions, and ruled that MetLife’s denial of the LTD benefits was not arbitrary and capricious. As such, the Court affirmed the district court’s judgment in MetLife’s favor.

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