A Massachusetts Federal Court recently held that MetLife wrongfully denied long term disability benefits and abused its discretion by failing to address contrary evidence and placing undue weight on certain evidence. The court remanded the case back to MetLife with specific instructions to re-evaluate the claim. This case was not handled by Attorneys Dell & Schaefer but it is a good victory for disability claimants suffering with fibromyalgia.
MetLife Failed to Address the Contrary Evidence
The Court pointed out three important pieces of evidence in the record that MetLife admitted it reviewed in rendering its decision to deny the Plaintiff’s LTD benefits, but failed to properly consider. The Plaintiff underwent a Functional Capacity Evaluation which revealed impairments in fine dexterity, range of motion, upper and lower body strength, overhead reaching and endurance. MetLife neither addressed those findings in its denial letter, nor did it provide any reason for dismissing those finding.
The Plaintiff also provided MetLife with a vocational assessment report which concluded that the Plaintiff would be unable to perform her occupational duties, or the occupational duties of any work for which she could reasonably qualify by education, training or experience, due to her functional impairment. Again, MetLife neither addressed the vocational assessment report nor did it provide any explanation to why it failed to consider the findings.
The Court also found that MetLife referenced certain notes by the Plaintiff’s treating physician, but failed to mention or give weight to other notes in which the treating physician found that there was objective medical evidence that the Plaintiff was functionally limited.
MetLife Failed to Consider the Plaintiff’s Disabling Symptoms and Instead Based the Denial on the Lack of a Clear Diagnosis
Moreover, the Court concluded that MetLife abused its discretion because instead of considering the Plaintiff’s functional limitations imposed by the Plaintiff’s disabling symptoms, MetLife based its denial on the fact that none of the Plaintiff’s treating physicians had been able to provide a definitive diagnosis for her neurological symptoms. MetLife’s medical consultants concluded that there was no basis for long term disability because there was no ‘objectively verifiable diagnosis that would account for her symptoms.” This is a fairly typical denial that the lawyers at Dell & Schaefer see on a routine basis from MetLife.
The Court also found that MetLife mischaracterized the evidence by stating that “many” of the Plaintiff’s treating physicians found her subjective complaints outweighed the objective findings when, in actuality, the medical evidence only revealed two instances where such comments were noted. The Court stated that MetLife made credibility judgments about the Plaintiff that were not supported by the record as a whole because none of the treating physicians ever suggested that the Plaintiff was malingering or exaggerating her symptoms.
As a result of these findings, the Court concluded that MetLife abused its discretion and that its denial of the Plaintiff’s claim for long term disability benefits was arbitrary and capricious. The case was remanded back to MetLife for further review.
Unfortunately, it is not uncommon for disability insurance companies to omit or mischaracterize medical evidence which might otherwise support that the claimant is unable to perform her occupational duties and is disabled. It requires the trained eye of an attorney experienced in ERISA disability cases carefully examining the claim file and medical evidence to catch these types of errors and omissions by the insurance company. If your claim for disability benefits has been denied by MetLife or any other disability insurance company, it is crucial to have the denial reviewed by an experienced attorney to ensure that you have not fallen victim to this type of unscrupulous claim handling practice.
If you have questions regarding your claim for disability benefits, or if your disability claim has been denied, feel free to call Disability Attorneys Dell & Schaefer for a free consultation.