Eleventh Circuit Affirms De Novo Disability Denial but Questions Whether Plan Conferred Discretion

In Wang v. Metropolitan Life Insurance Co., No. 25-11527, 2026 WL 1960673 (11th Cir. July 7, 2026), the Eleventh Circuit affirmed the entry of judgment for MetLife on a pro se participant’s ERISA claim for long-term disability benefits under a General Electric plan, holding that the denial was not wrong even under de novo review. Plaintiff ceased working in October 2022 after reporting shortness of breath, chest pain, and arrhythmia, and sought benefits on the basis of a stress-related heart condition. The Plan defined “total disability” to require, in relevant part, that the participant be unable because of illness or injury to perform the duties of his occupation within the first twelve months of absence, and thereafter to engage in any gainful occupation for which he was reasonably fitted.

The court declined to resolve the standard-of-review question the parties disputed. Plaintiff argued the Plan did not confer discretionary authority with sufficient clarity, while MetLife contended the Plan’s language required deferential arbitrary-and-capricious review. Because the district court had applied de novo review and MetLife prevailed under that standard, the panel found no need to remand. In a footnote, however, the court observed that Plaintiff “might be right” that the Plan did not expressly confer discretion, citing the Ninth Circuit’s holding in Abatie v. Alta Health & Life Insurance Co., 458 F.3d 955, 964 (9th Cir. 2006), that nearly identical language “merely identified the plan administrator’s tasks, but bestowed no power to interpret the plan,” as well as its own decision in Kirwan v. Marriott Corp., 10 F.3d 784, 788–89 (11th Cir. 1994). This observation was dictum and did not affect the outcome.

On the merits, the court held that Plaintiff failed to carry his burden of proving total disability. The treating physicians who opined that Plaintiff could not work rested on symptomatic premature ventricular contractions, but objective testing from a cardiologist and an electrophysiologist showed the PVCs were a benign condition unlikely to cause Plaintiff’s reported symptoms. Both treating physicians later signed statements agreeing with MetLife’s independent cardiologist that the symptoms were most consistent with anxiety rather than a cardiac condition. The court further found that the record contained only stray references to anxiety and depression, without any mental-health diagnosis, treatment by a mental-health provider, or opinion identifying restrictions attributable to a psychiatric condition. Because Plaintiff first raised mental-health conditions only in his second administrative appeal, the court found it unsurprising that MetLife had not addressed them earlier and reasonable that it required evidence of treatment.

The court denied Plaintiff’s motion to supplement the appellate record with four post-denial exhibits, including later treatment notes and an unfavorable Social Security determination. Although de novo review permits parties to introduce evidence outside the administrative record, the court explained that this latitude does not license disregard of a district court’s scheduling order and that supplementation on appeal is warranted only where the proffered material would establish beyond doubt the proper resolution of the issues. Three of the four exhibits were never submitted to the district court, the SSA determination was unfavorable, and post-denial treatment beginning in 2024 said little about disability dating to October 2022.

The court also rejected Plaintiff’s procedural challenges. It held that MetLife conducted a full and fair review, noting that each denial letter set out the definition of total disability and explained how the records fell short, and that MetLife did not shift its rationale during the appeals. Exercising de novo review, the court found it unnecessary to consider whether any conflict of interest affected the decision. It further observed that the governing regulation appears to require independence only between the initial adverse determination and the appeal, not between successive appeals, and that in any event a higher-level employee uninvolved in the first appeal reviewed and signed the second denial. Finally, the court held that the district court did not abuse its discretion in declining to impose sanctions or grant relief based on Plaintiff’s allegations of litigation misconduct, because active settlement negotiations did not extend the agreed dispositive-motion deadline and MetLife’s counsel timely provided filings Plaintiff said he had not received.