District Court Finds MetLife Improperly Terminated LTD Benefits Overly Relying on Selective Medical Reviews and Surveillance Footage

In LaLonde v. Metropolitan Life Insurance Company, No. 24-CV-01781-DSF-MBK, 2025 WL 1324139 (C.D. Cal. May 8, 2025), after a court trial on the administrative record, California Central District Judge Dale S. Fischer found that Plaintiff had demonstrated by a preponderance of the evidence his continued entitlement to long-term disability (“LTD”) benefits, under an ERISA-governed LTD Policy. Plaintiff is represented by Roberts Disability Law, P.C.

Plaintiff LaLonde, formerly employed by Providence Health & Services as a Manager, participated in a group disability insurance plan underwritten by MetLife. MetLife initially approved and paid LTD benefits to Plaintiff beginning in 2017 following an automobile accident and significant spinal surgery, as well as ongoing treatment for mental health conditions. However, MetLife terminated LaLonde’s benefits in 2019, citing insufficient evidence of continued disability either physical or mental. LaLonde appealed this decision, but MetLife upheld the termination. LaLonde then sought judicial review pursuant to ERISA.

At a bench trial on the administrative record, the court conducted a de novo review of MetLife’s benefits determination. The court concluded that MetLife’s determination was flawed because it (a) overemphasized what it deemed was insufficient objective evidence; (b) inconsistently applied surveillance footage first approving continued benefits and then denying, citing to the surveillance footage; (c) perplexingly focused on a lack of findings in right hip, when his condition was primarily in the spine and somewhat in the left hip; (d) failed to honor extension requests even after requiring that LaLonde contact his prior treating providers for opinions; and (e) failed to distinguish the Social Security Disability Insurance (SSDI) award and failed to note specifically that LaLonde needed to provide the full SSA file.

1. Medical and Physical Condition: The court found that LaLonde continues to suffer from spondylolisthesis, post-lumbar fusion surgery. These conditions, accompanied by chronic pain, were supported by consistent medical records, including reports of severe back and leg pain and the need for assistive devices.
2. Psychiatric Condition: LaLonde’s psychiatric conditions, including PTSD and depression, were supported by long-term treatment records. However, the court’s decision primarily focused on LaLonde’s physical limitations, which were independently disabling.
3. Surveillance and Functional Capacity: MetLife’s surveillance, which showed LaLonde performing limited activities, was previously deemed consistent with his reported restrictions. The court found MetLife’s later interpretation of this surveillance as evidence of “significant functioning” to be unsatisfactory, particularly given its earlier conclusions.
4. SSDI Award: LaLonde had been awarded SSDI benefits, indicating a recognition of his disability under a stringent federal standard. The court criticized MetLife for disregarding this award without adequate explanation, noting that the SSDI determination held evidentiary value.

In concluding that LaLonde had met his burden of demonstrating entitlement to LTD benefits by a preponderance of the evidence, the court afforded greater weight to the opinions of LaLonde’s treating providers because of their consistent report of functional limitations from his spinal condition and related chronic pain, and their greater opportunity to know and observe him. The court afforded less weight to MetLife’s physician reviews because they failed to grapple with the contrary reports and conclusions of LaLonde’s treating providers. MetLife’s physicians instead selectively focused on purported “inconsistencies” (i.e., whether LaLonde needed a walker, and periodic notations of a lack of abnormal findings). The court explained that such inconsistencies do not automatically negate a medical condition.

This decision underscores the importance of a comprehensive and balanced evaluation of medical evidence in ERISA disability cases. If MetLife or your disability insurer has denied or otherwise limited your ERISA benefits claim, contact us for assistance.