Michelle Cooper v. Metropolitan Life Insurance Co
2017 U.S. App. LEXIS 11933
| 8th Cir. | 2017Background
- Michelle Cooper, an employee of Anheuser-Busch, claimed long-term disability (LTD) benefits under the employer’s ERISA-governed group plan; MetLife funded and adjudicated claims.
- Cooper stopped working due to illness (diagnoses including SLE/lupus, Sjogren’s, chronic fatigue, migraines), submitted STD and later LTD claims supported by treating physician Dr. Rathod and chiropractor Dr. Lane.
- MetLife denied STD and then LTD claims, citing lack of objective clinical/diagnostic evidence to substantiate the functional limitations alleged by Cooper’s treating providers.
- On appeal MetLife obtained an independent rheumatologist (Dr. Schiopu) who reviewed the record and concluded there were insufficient objective findings to support disability; Cooper’s doctors were sent the report but did not respond.
- Cooper sued under ERISA § 502(a)(1)(B); the district court granted MetLife summary judgment applying the abuse-of-discretion standard and excluding two affidavits from Cooper’s treating providers as outside the administrative record.
- The Eighth Circuit affirmed: it found abuse-of-discretion review appropriate (with minimal weight to MetLife’s structural conflict), upheld exclusion of the affidavits, and concluded MetLife’s denial was reasonable and supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of review and conflict of interest | Glenn requires the court to reduce deference because MetLife both pays and evaluates claims | Plan language grants discretionary authority; conflict must be weighed but does not change the standard absent evidence of taint | Abuse-of-discretion review applies; MetLife’s conflict warranted little weight given procedural safeguards |
| Admissibility of post-decision affidavits | Affidavits from treating doctors challenging the independent reviewer’s report should be considered at summary judgment | Scope of review is limited to the administrative record; affidavits could have been submitted during the administrative appeal | District court properly excluded affidavits as not part of the administrative record |
| Denial of LTD benefits (substantial evidence/objective evidence) | Dr. Rathod’s treating opinions support disability and MetLife improperly favored an independent reviewer | MetLife relied on the record, neutral independent specialist, and permissible requirement of objective clinical evidence to substantiate functional limitations | Denial was not an abuse of discretion; MetLife’s decision was reasonable and supported by substantial evidence |
| Procedural compliance with DOL regulation on medical reviewers | MetLife erred by allowing a nurse (APNC) to screen lab/test results instead of a physician on appeal, warranting remand | Any regulatory error was harmless; substantial compliance and full-and-fair review occurred and APNC’s screening didn’t alter the outcome | Even if technical noncompliance occurred, it was harmless and did not require remand or reversal |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (establishes de novo default standard and discretionary-authorization exception)
- Metropolitan Life Ins. Co. v. Glenn, 554 U.S. 105 (conflict of interest is a factor in abuse-of-discretion review)
- Black & Decker Disability Plan v. Nord, 538 U.S. 822 (no special deference required to treating physician’s opinions)
- Pralutsky v. Metro. Life Ins. Co., 435 F.3d 833 (administrator may deny benefits for lack of objective evidence)
- Ingram v. Terminal R.R. Ass’n of St. Louis Pension Plan for Nonschedule Emps., 812 F.3d 628 (standard for reviewing abuse-of-discretion in this circuit)