Roganti v. Metropolitan Life Insurance
786 F.3d 201
| 2d Cir. | 2015Background
- Ronald Roganti, a long‑time MetLife executive, resigned in 2005 alleging pay cuts were retaliatory for his whistleblowing; he later sought relief in FINRA arbitration and from MetLife as plan administrator.
- In 2010 a FINRA panel awarded Roganti $2,492,442.07 in “compensatory damages” but did not specify whether the award constituted back pay, pension adjustments, or a lump sum for other harms.
- Roganti claimed the award was back pay (increasing his year‑by‑year compensation) and submitted a benefits claim to MetLife requesting pension recalculation; MetLife denied the claim because the award did not clearly allocate amounts to specific employment years or label the award as back pay.
- After administrative denial and remand, the district court held MetLife’s denial arbitrary and capricious, ordered benefits adjustment and denied Roganti’s fee request; MetLife appealed and Roganti cross‑appealed the fee denial.
- The Second Circuit reviews the plan administrator’s discretionary benefits decision under the arbitrary‑and‑capricious (abuse of discretion) standard and must weigh any conflict of interest as a factor.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the FINRA award constituted back pay (benefits‑eligible compensation) | Roganti: the award equals the difference between presumed "but‑for" pay (2002 level) and actual earnings for 2003–2005, i.e., back pay that should increase pensionable earnings | MetLife: the award is labeled general "compensatory damages," does not allocate amounts to years or instruct pension recalculation, so it is not clearly benefits‑eligible | Held: MetLife’s denial was not arbitrary and capricious — record did not conclusively show the award was back pay, so MetLife reasonably denied the claim |
| Whether MetLife acted arbitrarily by failing to produce an alternative mathematical allocation of the award on remand | Roganti: MetLife should have posited the award’s year‑by‑year allocation; silence undermines denial | MetLife: not obliged to reconstruct arbitrators’ intent; lack of award clarity is evidence against treating it as back pay | Held: MetLife was not required to supply its own allocation; denial was reasonable under deferential review |
| Effect of MetLife’s conflict of interest on standard/weight of review | Roganti: MetLife’s dual role (payor + administrator) should reduce deference and weigh against its decision | MetLife: took active steps (walls, separation, unrebutted affidavit) and Roganti offered no evidence showing the conflict affected the decision | Held: conflict exists but was entitled to little or no weight here; no evidence the conflict influenced the decision |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (Sup. Ct. 1989) (trust principles justify deferential review of administrator’s discretionary benefits decisions)
- Metropolitan Life Ins. Co. v. Glenn, 554 U.S. 105 (Sup. Ct. 2008) (conflict of interest is a factor in abuse‑of‑discretion review)
- Conkright v. Frommert, 559 U.S. 506 (Sup. Ct. 2010) (deference to plan administrators supports finality and efficiency in benefits disputes)
- Black & Decker Disability Plan v. Nord, 538 U.S. 822 (Sup. Ct. 2003) (administrators may not arbitrarily refuse to credit reliable evidence)
- Pagan v. NYNEX Pension Plan, 52 F.3d 438 (2d Cir. 1995) (standard for overturning discretionary administrator decisions: arbitrary and capricious)
- Durakovic v. Bldg. Serv. 32 BJ Pension Fund, 609 F.3d 133 (2d Cir. 2010) (discussion of decisionmaking deficiencies and weight to give administrator’s reasons)