Stacey Sanchez-Levine v. Metropolitan Life Insurance Company
2:16-cv-03179
C.D. Cal.Sep 26, 2017Background
- Plaintiff Stacey Sanchez-Levine was a patient account representative for Dignity Health who claimed disability beginning June 2, 2014 and was covered by MetLife’s group long-term disability (LTD) plan.
- The Plan required total disability during the 180‑day elimination period plus 24 months to mean inability to perform the substantial and material acts of her usual occupation with reasonable continuity.
- Sanchez‑Levine submitted medical records showing intermittent treatment for psychiatric conditions and orthopedic complaints (neck, shoulder, lumbar, alleged CTS); treating providers intermittently placed her off work between June 2014 and April 2015.
- MetLife reviewed the administrative record, obtained paper reviews from independent consultants (psychiatry and PM&R/internal medicine), concluded the evidence did not support disability throughout the elimination period, denied benefits, and upheld that denial on appeal.
- The district court performed a de novo review of the administrative record and concluded plaintiff failed to prove by a preponderance that she was totally disabled under the Plan; judgment entered for MetLife.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Sanchez‑Levine was "disabled" under the Plan from June 2, 2014 through the 180‑day elimination period and next 24 months | Sanchez‑Levine’s treating providers and supplementary records show she was unable to perform her job duties intermittently and thus disabled | MetLife argued the objective medical record (and independent reviews) did not show functional limits preventing performance of her desk job for the required continuous period | Held: Plaintiff failed to prove disability by a preponderance; denial proper |
| Whether MetLife properly relied on paper reviews and consultant opinions over treating physicians | Plaintiff contended treating‑provider opinions should control | MetLife maintained consultants’ thorough reviews of the records were reasonable and treating opinions were inconsistent and not dispositive | Held: Court accepted MetLife’s reliance on independent reviews as reasonable; no special deference to treating physicians required |
| Whether MetLife engaged in a "meaningful dialogue" and afforded plaintiff a full and fair review on appeal | Plaintiff argued MetLife failed to meaningfully communicate evidentiary needs | MetLife pointed to repeated phone calls, written status updates, and requests for records during initial and appellate review | Held: Communication was adequate; record showed MetLife informed plaintiff what records were needed and followed up |
| Standard of review applicable to denial under ERISA plan | Plaintiff implicitly favored heightened scrutiny or deference to treating docs | MetLife invoked standard allowing administrator discretion in evaluating evidence | Held: Court applied de novo review (per parties/court) and nevertheless found MetLife’s denial supported on the administrative record |
Key Cases Cited
- Abatie v. Alta Health & Life Ins. Co., 458 F.3d 955 (9th Cir. 2006) (standard for judicial review of ERISA benefit denials and discussion of abuse of discretion/de novo frameworks)
- Kearney v. Standard Ins. Co., 175 F.3d 1084 (9th Cir. 1999) (de novo review of ERISA benefit denial)
- Muniz v. Amec Constr. Mgmt., 623 F.3d 1290 (9th Cir. 2010) (burden on claimant to prove entitlement to benefits by a preponderance)
- Black & Decker Disability Plan v. Nord, 538 U.S. 822 (2003) (courts should not require plan administrators to give automatic special weight to treating physicians)
- Jordan v. Northrop Grumman Corp. Welfare Benefit Plan, 370 F.3d 869 (9th Cir. 2004) (medical diagnosis alone does not establish disability)
- Montour v. Hartford Life & Accident Ins. Co., 588 F.3d 623 (9th Cir. 2009) (review limited to administrative record used by plan administrator)
- Salomaa v. Honda Long Term Disability Plan, 642 F.3d 666 (9th Cir. 2011) (administrator must explain what additional evidence is needed when denying claim)
- Seleine v. Flour Corp. Long-Term Disability Plan, 598 F. Supp. 2d 1090 (C.D. Cal. 2009) (subjective pain reports require objective support; administrator not bound to accept subjective complaints)
- Armani v. Northwest Mut. Life Ins. Co., 840 F.3d 1159 (9th Cir. 2011) (functional limitations such as inability to sit for more than half the workday can preclude a mostly sedentary job)