Central District of California Grants LTD Benefits After Finding MetLife Ignored Credible Medical Evidence of Long-Haul COVID Disability

In Baltes v. Metropolitan Life Insurance Co., Case 2:23-cv-07404-MRA-JPR (C.D. Cal. Nov. 12, 2025), the U.S. District Court for the Central District of California granted judgment in favor of a Google software engineer whose claim for long-term disability (“LTD”) benefits had been denied by MetLife. Conducting a de novo review under Federal Rule of Civil Procedure 52, the court found that the plaintiff established by a preponderance of the evidence that he was “Totally Disabled” during the Plan’s elimination period due to cognitive impairment, fatigue, and post-viral complications consistent with long-haul COVID-19.

The court’s opinion highlights several recurring ERISA claim issues: the reliability of treating-physician evidence, improper reliance on “paper reviews,” the role of subjective symptoms without objective markers, and an insurer’s obligation to consider the specific duties of a claimant’s occupation.

Background

The plaintiff, a Senior Software Engineer at Google, contracted COVID-19 twice and subsequently experienced severe fatigue, brain fog, impaired concentration, and cognitive limitations. Multiple treating providers—including an osteopathic physician, a naturopathic doctor, and specialists at a long-COVID treatment center—documented persistent symptoms, abnormal cytokine markers, toxicology results, and SPECT neuroimaging indicative of impaired brain functioning.

While Sedgwick approved his short-term disability claim, MetLife denied his LTD claim, asserting a lack of “objective evidence” of functional impairment. MetLife relied on two physician file reviewers who never examined the claimant, did not review his full medical record, and were not provided with his job description.

On appeal, the plaintiff submitted substantial additional evidence, including treating-physician letters, functional descriptions, and diagnostic testing. MetLife nonetheless upheld the denial.

Standard of Review

The parties stipulated that the court’s review would be de novo, meaning the court owed no deference to MetLife’s benefit determination. Under this standard, the court independently assessed whether the evidence showed the plaintiff was unable to perform the “Substantial and Material Acts” of his “Usual Occupation” with reasonable continuity, as required by the Google LTD Plan.

Court’s Analysis

1. Plaintiff’s Self-Reported Symptoms Were Credible and Consistent

The court found the plaintiff’s reporting of fatigue, cognitive dysfunction, and difficulty with daily functioning credible, noting that ERISA does not allow an insurer to disregard subjective symptoms unless the plan explicitly requires objective proof—something this Plan did not do.

MetLife attempted to undermine credibility by noting the plaintiff had attended a conference and one social event while on leave. The court rejected this logic, explaining that isolated activities do not undermine disability where the claimant cannot sustain function on a regular, work-like schedule.

2. Treating-Physician Opinions Were More Reliable Than File Reviewers

The court assigned significant weight to the opinions of the plaintiff’s treating physicians, who consistently documented debilitating symptoms and relied on:

• repeated clinical encounters
• cytokine panel testing showing markers consistent with long-COVID
• toxicology results with elevated metals
• SPECT neuroimaging showing impaired brain function
• psychometric testing
• longitudinal symptom reporting

The court rejected MetLife’s argument that normal physical exams undermined these findings, noting—as many courts have—that chronic fatigue and long-haul COVID are conditions often diagnosed through patient-reported symptoms supported by exclusionary testing, not classic objective markers.

3. MetLife’s Paper Reviewers Lacked Credibility

MetLife relied on two consultants who:

• conducted only file reviews,
• never examined the claimant,
• did not review his full medical file, and
• were not given his actual job description, despite the Plan requiring disability to be assessed relative to job duties.

The court emphasized Ninth Circuit precedent criticizing paper reviews, particularly where the reviewers make credibility judgments about subjective illnesses like long-haul COVID or chronic fatigue.

4. MetLife Mischaracterized or Ignored Key Medical Evidence

The court highlighted multiple ways in which MetLife:

• overstated the significance of “normal” exam results;
• failed to address extensive laboratory and imaging evidence;
• relied on a non-physician receptionist’s statement to claim the treating physician had “released” the claimant to work—something the physician categorically denied; and
• introduced new rationales during litigation that were never disclosed to the claimant during the administrative process.

5. Plaintiff Was Unable to Perform His Job as a Senior Software Engineer

Using Google’s detailed job description, the court found the plaintiff could not perform critical tasks such as:

• writing and reviewing code,
• managing complex project deliverables,
• maintaining concentration for extended periods, or
• performing cognitive-intensive problem-solving.

Given his documented inability to use a computer for sustained periods and debilitating post-exertional fatigue, he could not “perform with reasonable continuity the Substantial and Material Acts” of his occupation.

Holding

The court held that the plaintiff was Totally Disabled under the terms of the Plan, granted his Rule 52 motion, and denied MetLife’s cross-motion. The plaintiff is therefore entitled to LTD benefits for the relevant period.

Key Takeaways

• Long-haul COVID and chronic fatigue claims cannot be denied for lack of objective evidence when the plan does not require it and the condition itself lacks definitive objective markers.
• Treating-physician opinions—when consistent and supported by testing—outweigh paper reviews.
• Insurers must consider the actual job duties, not generic job titles or assumptions.
• Mischaracterizing evidence, ignoring test results, or introducing new rationales in litigation violates ERISA’s fair notice requirements.
• Courts continue to scrutinize disability claim reviews involving subjective symptoms or novel conditions such as long-COVID.