Fifth Circuit Upholds MetLife’s Termination of Long-Term Disability Benefits

In Stout v. Smith Int’l, Inc., No. 24-30571, 2025 WL 1029503 (5th Cir. Apr. 7, 2025), a dispute involving a claimant’s continued eligibility for long-term disability (“LTD”) benefits under a plan governed by the Employee Retirement Income Security Act of 1974 (“ERISA”), Plaintiff-Appellant Stout appealed the district court’s decision to grant summary judgment in favor of Defendants. Stout was a participant in the disability plan sponsored by Smith International, and insured and administered by MetLife. Stout initially went out on disability due to valvular heart disease, aortic and mitral stenosis and regurgitation, hypertension, and associated co-morbidity conditions. His cardiologist, Dr. Esmond Barker, recommended that he not lift more than 25 pounds. MetLife found that Stout qualified as disabled under the terms of the disability plan and awarded him LTD benefits. However, subsequent evaluations revealed improvements in Stout’s condition, prompting MetLife to reassess his eligibility. Dr. Stanley Chou, an internal medicine doctor with expertise in cardiovascular disease, reviewed Stout’s medical records and concluded that he was capable of full-time work. Dr. Barker later agreed with Dr. Chou’s assessment, leading MetLife to terminate the benefits. Stout filed suit in the United States District Court for the Western Disatrict of Louisiana. The court ruled for MetLife and Stout appealed.

The Fifth Circuit Court of Appeals reviewed the district court’s summary judgment decision de novo, acknowledging that the standard of review—whether de novo or abuse of discretion—was not crucial to the outcome. The Court focused on the administrative record, which included opinions from multiple doctors, all of whom agreed that Stout was not sufficiently impaired to warrant restrictions. The Court emphasized that under the terms of the disability plan, benefits would end if Stout was no longer considered disabled, defined as being unable to earn more than 60% of his predisability earnings due to illness or injury. With no evidence supporting continued disability, the Court determined that a reasonable fact finder could not conclude that Stout was entitled to the benefits, thus affirming the district court’s decision.

If MetLife has denied your long-term disability benefits, contact us for assistance with your appeal.