Eleventh Circuit Rules MetLife Properly Terminated Attorney’s Disability Benefits

In Hovan v. Metropolitan Life Insurance Company, No. 24-11167, 2025 WL 3241521 (11th Cir. Nov. 20, 2025), the Eleventh Circuit affirmed summary judgment for MetLife, upholding the insurer’s termination of long-term disability benefits previously paid to a commercial litigator who suffered from bipolar disorder. The court held that MetLife’s decision was not de novo wrong under the Blankenship framework and that the claimant failed to meet her burden to prove continued disability beyond October 2020.

Hovan, a commercial litigator at Troutman Sanders LLP, received long-term disability benefits beginning in June 2019 following a bipolar-related mental health crisis. Her job required complex analytical work, judgment, decision-making, and high interpersonal functioning.

Under the ERISA-governed plan, attorneys are considered disabled if they cannot perform “each of the material duties” of their specialty. After a partial hospitalization program ended in October 2020, MetLife reviewed her continued eligibility.

Hovan’s sole post-treatment evidence consisted of therapy notes from November 2020–March 2021. These records documented mood fluctuations and occasional passive suicidal thoughts, but repeatedly recorded intact cognition, appropriate affect, interactive interpersonal functioning, and no described occupational limits. The therapist did not opine on work capacity.

MetLife terminated benefits effective October 16, 2020, and its consulting psychiatrist concluded that no functional restrictions were supported. On appeal, MetLife invited Hovan—represented by counsel—to submit additional evidence. She declined. The district court affirmed MetLife’s decision after de novo review, and Hovan appealed.

At step one of the six-part Blankenship test, the Eleventh Circuit asked whether MetLife’s decision was “de novo wrong.” It held it was not wrong, ending the analysis.

The court found that the therapy notes reflected symptoms associated with bipolar disorder, but did not identify occupational restrictions or cognitive deficits preventing high-level litigation work. The therapy notes showed consistent notations of intact functioning and documented passive suicidal ideation that was “fleeting” and without plan or intent. Compared to earlier 2019 records—where a psychiatrist documented significant impairments—the later therapy notes lacked evidence of the type of functional limitations required to show disability in Hovan’s specialty.

Hovan, not MetLife, had the obligation to produce evidence of continued disability. The court emphasized that MetLife permissibly required proof of occupational limitations, Hovan declined the opportunity to provide more medical documentation, and arguments attacking MetLife’s reliance on a file-review psychiatrist failed because administrators may rely on such reviews.

Because MetLife’s decision was not wrong under de novo review, the court did not reach later Blankenship steps regarding discretion, reasonableness, or conflicts of interest. The Eleventh Circuit affirmed: Hovan failed to establish that she remained disabled under the plan after October 16, 2020, and MetLife acted properly in terminating benefits.