In Seneca v. Metropolitan Life Insurance Company, No. CV 23-00109-BAJ-SDJ, 2024 WL 4335925 (M.D. La. Sept. 27, 2024), Louisiana Middle District Judge Brian A. Jackson granted judgment in favor of MetLife and against Plaintiff, finding that MetLife had not abused its discretion in concluding that Plaintiff was no longer totally disabled under the terms of the ERISA policy as of the date it terminated benefits.
Plaintiff was employed as an IT Administrator with HP, Inc., with job duties consisting of maintaining approximately 200 printers and performing occasional onsite repairs of the same. In the course of his duties, Plaintiff was required to routinely walk, bend, stand, and lift printers. Plaintiff stopped working on March 17, 2018, due to rheumatoid arthritis and neuropathy. MetLife approved and began paying LTD benefits effective September 13, 2018. It terminated benefits after 24 months after an independent medical reviewer, Dr. Mahdy Flores, determined that Plaintiff’s condition was not of such severity to warrant the placement of restrictions beyond the 24-month own occupation period. MetLife upheld its decision on appeal after a second independent medical reviewer, Dr. Roger Belcourt, also concluded that Plaintiff was not suffering from a limiting or restrictive medical condition as of September 13, 2020. This litigation followed.
Under an abuse of discretion standard, the Court found that Plaintiff did not carry his burden to prove, by a preponderance of the evidence that MetLife’s actions were arbitrary or capricious, or that its decision to terminate Plaintiff’s benefits was not rationally connected to the known facts. Rather, the Court concluded that MetLife’s decision was supported by substantial evidence. The Court summarized that when Plaintiff first became disabled in March 2018, one of Plaintiff’s treating physicians determined that Plaintiff suffered from rheumatoid arthritis and neuropathy and could return to work in approximately six months. This physician never substantively altered this conclusion. After receiving benefits for two years, the definition of total disability was changed by the terms of the Plan, so that now Plaintiff needed to demonstrate that he was unable to engage with reasonable continuity in any occupation which he could reasonably be expected to perform given his age, education, training, experience, station in life, and physical and mental capacity. Plaintiff’s medical records showed that in 2019 and 2020, his limiting disabilities were changed to psoriatic arthritis and neuropathy, and that these conditions were either in remission or controlled by medication. Plaintiff’s visits with his then primary care physician were unremarkable, and Plaintiff did not report significant pain or painful joints, weakness, tingling or numbness. Only one of Plaintiff’s physicians, a cardiologist, ever concluded that Plaintiff was totally disabled for an indefinite period of time. But even this treating physician noted in July 2020 that Plaintiff’s back was feeling better, he reported no pain, and his neuropathy was stable on medication.
The Court found that the conclusions of both medical reviewers, Drs. Flores and Betancourt, were not contrary to the evidence in the records, as the two years of medical evidence demonstrated that Plaintiff’s condition had improved markedly, and not a single physician recommended that Plaintiff be restricted from all work. The Court further found that it was not unreasonable for MetLife to refuse to come to the same conclusion of the ALJ where the decision was considered and distinguished by the available medical evidence. In sum, the Court found that the opinions of the medical professionals who concluded that Plaintiff was no longer disabled each had a cogent and factual basis for reaching this conclusion, and the decision was rationally connected to the known facts.
If MetLife or your insurer has denied or otherwise limited your disability insurance claim, contact us for assistance.
*Please note that this blog is a summary of a reported legal decision and does not constitute legal advice. This blog has not been updated to note any subsequent change in status, including whether a decision is reconsidered or vacated. The case above was handled by other law firms, but if you have questions about how the developing law impacts your ERISA benefit claim, the attorneys at Roberts Disability Law, P.C. may be able to advise you so please contact us.
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