757 F.3d 452
5th Cir.2014Background
- Harvey McCorkle died in January 2010; Loy McCorkle seeks Plan benefits under ERISA-governed AD&D and life coverages from MetLife (plan administrator) and Turner Industries; MetLife denied most benefits as suicide or self-inflicted death; death certificate lists suicide and EBRSD reports show self-inflicted gunshot with no third-party involvement; Loy appealed administratively, including Lunesta-related arguments; district court ruled MetLife abused its discretion and granted Loy full benefits, later reversed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MetLife abused its discretion in denying Loy's claim | Loy argues Lunesta caused behavior, negating intent to self-harm | MetLife relied on substantial evidence showing suicide despite Lunesta effects | No abuse of discretion; suicide supported by substantial evidence |
Key Cases Cited
- Holland v. Life Ins. Co. of Am., 576 F.3d 240 (5th Cir. 2009) (abuse standard and deference in ERISA reviews; weighing evidence must be reasonable)
- Anderson v. Cytec Indus., Inc., 619 F.3d 505 (5th Cir. 2010) (conflict of interest factors; deference in review remains even with potential conflicts)
- Ellis v. Liberty Life Assurance Co. of Boston, 394 F.3d 262 (5th Cir. 2004) (substantial evidence standard for plan administrator decisions)
- Truitt v. Unum Life Ins. Co. of Am., 729 F.3d 497 (5th Cir. 2013) (abuse-of-discretion review; not substituting own judgment for administrator's)