Michigan Federal Court Reinstates ERISA Long-Term Disability Benefits After Insurer Applied the Wrong Plan Definition

In Fitzgerald v. Metropolitan Life Insurance Company, No. 23-13169, 2026 WL 1990460 (E.D. Mich. July 9, 2026), District Judge David M. Lawson granted judgment to a former automotive production worker whose ERISA-governed long-term disability benefits MetLife had terminated, holding that MetLife improperly denied the claim by applying the wrong plan definition of disability and by crediting file-review reports that failed to engage the central evidence of Plaintiff’s psychiatric impairment. The court awarded benefits for the remaining months of the plan’s benefit period rather than remanding to the administrator.

Plaintiff worked for nearly ten years as a machine operator before severe psychiatric illness, including major depressive disorder, bipolar disorder, and generalized anxiety disorder, stopped him from working in 2015. MetLife approved his ERISA long-term disability claim in 2016 and paid benefits for roughly four years before terminating them in December 2020. After an unsuccessful administrative appeal, Plaintiff sued under ERISA Section 502(a)(1)(B). The parties agreed the court’s review was de novo.

Which version of the ERISA plan governed the disability claim?

The administrative record contained two certificates: a 2011 certificate with a broader “any gainful occupation in the local economy” disability definition but a longer benefit duration, and a 2016 certificate with a narrower definition tied to covered work at the employer but a 60-month maximum benefit period. MetLife applied the 2011 certificate when it terminated benefits. The court held the 2016 certificate governed. Plaintiff applied for benefits in 2016, MetLife approved the claim under the 2016 certificate’s definition, MetLife produced the 2016 certificate when Plaintiff’s counsel requested the governing plan documents, and MetLife’s own claim activity logs applied the 2016 definition throughout its administration of the claim. Only as it moved to terminate benefits did MetLife switch to the less favorable 2011 definition.

Did Plaintiff prove he remained disabled under the governing ERISA definition?

The court held that he did, as to his psychiatric conditions. Under the 2016 certificate, Plaintiff needed to show his conditions prevented him from performing covered work at his employer. MetLife’s own earlier determinations framed the inquiry: from the outset, MetLife had found that Plaintiff’s severe depression and anxiety prevented him from performing his job class because he could not control his emotions, work effectively with others, or exercise sound judgment. The question was whether those same limitations persisted. The court found they did. Plaintiff’s treating psychiatrist, Dr. Lathia, completed a functional questionnaire concluding that Plaintiff remained unable to regulate his emotions or maintain concentration across a normal workday, and the court treated that questionnaire as critical objective evidence. Plaintiff’s therapist and primary care physician documented a consistent clinical picture of depressed and anxious mood, agitation, and impaired functioning. The court found Plaintiff came up short on his physical conditions, as every reviewer, including his own primary care physician, imposed no work restrictions on that basis, but the psychiatric evidence carried his burden.

Why did the court reject MetLife’s file-review consultant reports?

MetLife relied on four consultants who reviewed the file without examining Plaintiff. The court found their psychiatric analyses incomplete. The consultants emphasized Plaintiff’s intact memory, judgment, and organized thought during office visits but never addressed Dr. Lathia’s central finding that Plaintiff remained unable to regulate his emotions or sustain concentration over a full workday despite those intact in-visit findings. The court noted the Sixth Circuit’s recognition that file reviews are questionable for identifying disability from mental illness, because mental health evaluation depends on subjective symptoms best assessed through examination. The court also found the reports effectively heightened the plan’s standard by faulting Plaintiff for the absence of involuntary hospitalization or suicidal ideation, neither of which the plan required.

Did the court remand or award benefits?

The court awarded benefits rather than remanding. Remand is appropriate where the problem lies with the integrity of the decision-making process rather than a clear entitlement wrongly denied. Here, the court found the record established that Plaintiff remained disabled throughout the relevant period and that nothing suggested further proceedings would change that result. Because the 2016 certificate capped benefits at 60 months and Plaintiff began receiving benefits in October 2016, his entitlement expired in October 2021. The court awarded unpaid benefits from the December 15, 2020 termination through October 24, 2021, and directed Plaintiff to submit a supplemental filing calculating the amount.