If Metropolitan Life Insurance Company (“MetLife”) has denied your claim for long-term disability benefits, then the story behind this recent court decision, Hamid v. Metro. Life Ins. Co., No. 20-CV-01601-VC, 2021 WL 405225 (N.D. Cal. Feb. 5, 2021), may sound familiar to you.
At the age of 35, Plaintiff Hamid had been working as a successful professional in the mortgage brokerage industry for 15 years before he was forced to stop working because of severe migraines, allergies that caused facial swelling and pain, and sinus pain—symptoms so severe that the Social Security Administration likened them to epilepsy characterized by dyscognitive seizures. Mr. Hamid’s work ethic earned him promotions and opportunities at multiple large banks, including his most recent management position at Bank of America. He was enjoying the prime of his career while supporting his young family. But after a worsening of recurrent migraine- and sinus-related symptoms including extreme fogginess and difficulty concentrating, severe congestion, head pain, and facial pain and swelling, Mr. Hamid was forced to stop working. He underwent a variety of treatments including prescribed pharmaceuticals, allergy injections, prescribed Botox injections, facial steroid injections, as well as multiple surgeries in attempts to improve his symptoms. Despite all these medical interventions, Mr. Hamid’s condition did not improve. He was forced to give up a job he loved.
At the time of his disability, Mr. Hamid was a participant in the Defendant Bank of America Group Benefits Program, a health and welfare benefit plan governed by the Employee Retirement Income Security Act of 1974 (“ERISA”). The Program’s short-term disability (“STD”) benefits are administered by Defendant MetLife. MetLife also insures and administers the Program’s long-term disability (“LTD”) benefits. Mr. Hamid submitted claims with MetLife for both STD and LTD benefits, which MetLife denied despite extensive supporting documentation including medical records, supporting letters from treating providers, a favorable Social Security Administration determination of disability, and numerous supporting third-party declarations.
The district court determined that MetLife not only incorrectly decided Mr. Hamid’s long-term disability claim, but that its denial was an “abuse of discretion.” The court explained that “MetLife rejected Hamid’s consistent reports of pain, corroborated and credited by his treating physicians, based on the opinion of hired consultants—who never met Hamid in person—that insufficient objective evidence substantiated his pain, and without grappling with the contrary conclusion reached by the Social Security Administration on the same medical record.”
First, “in the context of Hamid’s prolonged and consistently documented reports of chronic pain and headache symptoms, MetLife was wrong to insist on ‘objective’ and ‘clinical’ evidence as a prerequisite for disability benefits.” Certain conditions, like chronic headache or migraine pain are not shown by “objective” indicators like lab reports or imaging scans. MetLife and its reviewing doctors focused exclusively on “normal” readings of various exams and essentially disregarded his complaints of severe pain.
Second, the court found that Mr. Hamid’s subjective reports of pain were credible because “his doctors continued to credit his reported symptoms by recommending and implementing new treatment options, including relatively drastic ones such as surgery and opioids.” The only people to discount his pain symptoms were MetLife’s paid doctors. The court found that the prescription of numerous powerful drugs constitutes objective evidence of Mr. Hamid’s impairment.
Third, the court found that it was notable that the SSA granted Mr. Hamid SSDI benefits on essentially the same medical record. MetLife only briefly acknowledged the SSA decision and its consultants’ review of the SSA file “seemed to be little more than a check-the-box afterthought.” MetLife’s dismissal of the SSA decision as being “based on different standards than the Plan” offered nothing of substance.
The court found that Mr. Hamid met his burden of proof and is entitled to STD benefits and 24 months of LTD benefits under the own occupation standard of disability (which is the applicable definition of disability as of the date of judgment).
Michelle Roberts represented Mr. Hamid in the federal district court proceedings. Ms. Roberts has helped many clients overturn MetLife claim denials. She also prevailed against MetLife in Demer v. IBM Corp. LTD Plan, 835 F.3d 893 (9th Cir. 2016) and Zewdu v. Citigroup Long Term Disability Plan, 264 F.R.D. 622 (N.D. Cal. 2010). If MetLife has wrongfully denied your LTD claim, contact us for a case evaluation.
*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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