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Home > Blog > Blog > Long Term Disability > District Court Reverses Insurer’s Denial of ERISA Long-Term Disability Benefits, Finding Claimant Was Disabled Prior to His Termination from Employment Due to Reduction in Workforce

District Court Reverses Insurer’s Denial of ERISA Long-Term Disability Benefits, Finding Claimant Was Disabled Prior to His Termination from Employment Due to Reduction in Workforce

In Dharmasena v. Metro. Life Ins. Co., No. EDCV 23-01510 JGB (DTBX), 2025 WL 1563970 (C.D. Cal. May 29, 2025), a lawsuit brought under the Employee Retirement Income Security Act (ERISA), California Central District Judge Jesus G. Bernal reversed Metropolitan Life Insurance Company’s (MetLife) decision to deny long-term disability benefits to an engineer with significant physical impairments. The court granted Plaintiff’s motion for judgment pursuant to FRCP Rule 52.

Dharmasena, an electrical engineer at Schneider Electric Inc., was diagnosed with Facioscapulohumeral Muscular Dystrophy (FSHD) and chronic kidney disease, significantly impacting his ability to work. After being terminated due to a reduction in force, Dharmasena submitted a claim for long-term disability benefits. MetLife denied the claim, stating that his disability date began after his termination, thus disqualifying him from benefits based on the plan’s terms.

The court conducted a de novo review of the claim without any deference to MetLife’s previous decision. MetLife’s principal argument for denial was based on the timing of Dharmasena’s disability claim. It contended that because Dharmasena’s disability was claimed to start on February 7, 2022, after his termination on February 4, 2022, he was not eligible for benefits. The court, however, dissected this reasoning and highlighted that the evidence did not support a strict interpretation of the disability start date. It recognized that disability could manifest while an employee is still working, especially as Dharmasena’s medical condition was progressively deteriorating, making him unable to perform his job effectively even before the formal date of termination. While MetLife emphasized policy technicalities and dates, the court’s decision leaned on a broader interpretation of disability, recognizing real-world implications over rigid administrative timelines.

Next, the court turned to the substantive basis for Dharmasena’s disability claim, examining the evidence, which included medical records, vocational assessments, and a Social Security Administration (SSA) disability award. The court placed significant weight on the medical documentation provided by Dharmasena’s primary care doctor, Dr. Win. During an appointment shortly after Dharmasena’s termination, Dr. Win noted that Dharmasena had severe physical limitations, including difficulty sitting and using his upper extremities. These observations were critical in establishing that Dharmasena was likely disabled on his last working day. Dr. Win’s findings were supported by Dharmasena’s functional capacity evaluations, which emphasized his inability to perform even sedentary work due to his condition.

The court further noted the importance of the SSA’s determination that Dharmasena was disabled as of February 4, 2022. Despite the SSA’s disability criteria being stricter than those in the plan, this award reinforced the claim that Dharmasena was unable to work at the required capacity before his termination. The court recognized the SSA’s decision as “weighty evidence,” reflecting a thorough assessment of Dharmasena’s impairments.

A pivotal aspect of the court’s analysis was interpreting the plan’s disability definition. The court clarified that under the plan, a participant could still be considered disabled even if they continued working. The plan focused on the ability to earn a specified percentage of predisability earnings, rather than the act of working itself. This interpretation opened the door for retroactive claims, highlighting that a disability claim can be valid even if the claimant was employed and earning income at the time.

The court concluded that Dharmasena was disabled within the meaning of the plan as of his last working day and entitled to long-term disability benefits, emphasizing that MetLife’s reasons for denial did not adequately address the comprehensive medical evidence demonstrating Dharmasena’s limitations.

If MetLife or your disability insurer has denied or otherwise limited your ERISA benefits claim, contact us for assistance.

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*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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