Thomas Judge v. Metropolitan Life Insurance Co.
710 F.3d 651
| 6th Cir. | 2013Background
- Judge sought ERISA disability benefits from MetLife under a group policy; MetLife denied benefits as not totally and permanently disabled; Plan defines disability as inability to perform own and any other job for which educated/trained; internal review and appeals occurred; nurse reviewers found no objective evidence supporting sitting/standing restrictions; district court granted MetLife, and Sixth Circuit affirmed the denial with this opinion; dissent by Moore partially concurs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MetLife used the correct disability standard | Judge argues MetLife applied wrong standard | MetLife corrected to proper standard in final denial | No reversible error; final standard applied was correct or harmless error. |
| Whether vocational evidence was required | Judge contends vocational expert needed to show broader employability | Plan not required to obtain vocational evidence when medical record supports denial | MetLife not required to obtain vocational evidence. |
| Whether independent medical examination was required | Judge asserts need for independent medical exam | File review acceptable where plan reserved right to physical exam | File review upheld; no EIM required. |
| Whether conflict of interest affected decision | MetLife’s dual role as administrator and payor creates bias | Conflict weight is one factor; no substantial bias shown | Conflict of interest factor given little weight; decision affirmed. |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (Supreme Court 1989) (set standard for review of ERISA benefit determinations)
- Davis v. Ky. Fin. Cos. Ret. Plan, 887 F.2d 689 (6th Cir. 1989) (arbitrary-and-capricious review defined)
- Yeager v. Reliance Standard Life Ins. Co., 88 F.3d 376 (6th Cir. 1996) (limits on administrative record review)
- Douglas v. Gen. Dynamics Long Term Disability Plan, 43 F. App’x 864 (6th Cir. 2002) (vocational evidence not required under ERISA (before social-security context))
- Elliott v. Metropolitan Life Ins. Co., 473 F.3d 613 (6th Cir. 2006) (illustrates improper reliance on incorrect standard and need for proper evaluation)
- Kent v. United of Omaha Life Ins. Co., 96 F.3d 803 (6th Cir. 1996) (remand not required where evidence supports decision)
- Kalish v. Liberty Mut./Liberty Life Assurance Co., 419 F.3d 501 (6th Cir. 2005) (sedentary work may not preclude disability when occupation requires standing/walking)