Blankenship v. Metropolitan Life Insurance
644 F.3d 1350
| 11th Cir. | 2011Background
- Blankenship worked for Sears in an ERISA long-term disability plan administered and funded by MetLife, which has discretionary interpretive authority over the plan.
- MetLife denied Blankenship's long-term disability benefits after treating events from 2003 to 2006, including a heart attack and later knee surgery.
- The plan provides two tests for disability: Own Occupation (first 2 years) and Any Occupation (thereafter); MetLife applied the Any Occupation standard.
- MetLife relied on independent medical opinions and vocational assessments to deny eligibility for further benefits in 2006, after appeals.
- Blankenship sued under ERISA to recover benefits; the district court found MetLife's decisions arbitrary and capricious due to a structural conflict of interest, and the Eleventh Circuit reversed and remanded.
- The Eleventh Circuit applied the Williams framework, held the conflict was a factor but did not render the decisions unreasonable, and remanded with instructions to enter judgment for MetLife.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MetLife's denial was reasonable under ERISA’s framework | Blankenship argues the conflict tainted the denial | MetLife contends decisions had a reasonable basis | Yes; MetLife's decisions were reasonable and not arbitrary and capricious. |
| Role of structural conflict of interest in review | Conflict should overturn the decision | Conflict is only a factor to consider | Conflict considered as a factor; not sufficient to overturn the decision. |
| Appropriateness of medical evidence weighting | Treating physicians' opinions should govern | Independent opinions may be given greater weight | Reasonable to credit independent opinions over treating physicians. |
Key Cases Cited
- Capone v. Aetna Life Insurance Co., 592 F.3d 1189 (11th Cir. 2010) ( Williams framework modification and conflict consideration in ERISA review)
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (U.S. 1989) (established standard for ERISA de novo review and deferential review)
- Glenn v. Life and Health Insurance Co., 554 U.S. 105 (U.S. 2008) (conflict of interest as a factor in review under Williams)
- Doyle v. Liberty Life Assurance Co. of Boston, 542 F.3d 1352 (11th Cir. 2008) (confirms deference to discretionary plan decisions with conflict as a factor)
- Jett v. Blue Cross & Blue Shield of Ala., Inc., 890 F.2d 1137 (11th Cir. 1989) (ERISA arbitrary-and-capricious review standard)
- White v. Coca-Cola Co., 542 F.3d 848 (11th Cir. 2008) (emphasizes that reasonable basis upholds administrator decisions despite contrary evidence)