US supreme court attempts to clarify the standard of review in denial of long term disability benefits
On June 19, 2008, the Supreme Court of the United States finally issued their opinion in the case of Wanda Glen v. Met Life. In a 6 to 3 decision announced Thursday, the US Supreme Court ruled that benefit denials by such companies must be examined with caution when circumstances suggest a high likelihood that financial considerations affected a benefits decision. While Ms. Glenn won her case and Met Life was ordered to pay long-term disability benefits, the Supreme Court did not make any significant findings that will change the way that Federal courts must interpret disability benefit denials. The Supreme Court had an opportunity to modify the standard of review to “de novo” (complete review) in all conflict of interest disability claim denials, however they did nothing to give employees a better chance of securing disability benefits that have been denied.
Judges must approach medical disability and health insurance disputes with a skeptical eye when they involve insurance companies that both evaluate and pay employee claims.
The court added that an apparent conflict of interest is only one of many factors that a reviewing judge must consider.
The ruling is important because it offers guidance to federal judges presiding over lawsuits challenging medical disability and health insurance determinations in group policies.
“When judges review the lawfulness of benefit denials, they will often take account of several different considerations of which a conflict of interest is one,” writes Justice Stephen Breyer in the majority opinion.
The decision, in Metlife v. Glenn, comes in the case of an Ohio woman diagnosed with a severe heart condition, who had her disability benefits withdrawn by the Metropolitan Life Insurance Co.
A federal judge upheld the denial of benefits, but the Sixth US Circuit Court of Appeals reversed that finding, ruling that the judge had not fully considered the impact of MetLife’s potential conflict of interest in both administering the plan and deciding which claims to pay and which to deny.
Justice Breyer said the appeals court followed the correct “combination-of-factors method of review.” He said judges should examine the record for potentially inconsistent positions taken by a company, and whether the company gave due weight to the entire record or favored certain reports while downplaying others.
Three justices dissented. Justice Antonin Scalia wrote that the court was giving too much weight to an appearance of conflict. He said that under the law of trusts “[A] fiduciary with a conflict does not abuse its discretion unless the conflict actually and improperly motivates the decision.” He adds, “There is no evidence of that here.”
Dissents were also filed by Justices Anthony Kennedy and Clarence Thomas.
In passing the Employee Retirement Income Security Act of 1974 (ERISA), Congress authorized insurance companies to both evaluate and pay claims. ERISA also authorizes employees to file a lawsuit in federal court challenging an unfair denial of benefits.
But ERISA doesn’t set a clear standard for judges who are called upon to decide disputes over benefits.
In 1989, the Supreme Court ruled that judges hearing such lawsuits must apply a more rigorous standard of review in cases in which the plan administrator served as both the evaluator and payer of claims.
But the court did not explain what constitutes a conflict of interest or how federal judges should weigh such a conflict while considering a particular case.
Thursday’s decision stems from the case of Wanda Glenn, a sales manager at a Sears store from 1986 to 2000. In 2000, her physician diagnosed a severe heart condition. He advised that she no longer work. She applied for disability benefits under Sears’ plan, administered by MetLife.
On the basis of the diagnosis and the physician’s recommendation, MetLife found that Ms. Glenn was totally disabled and began paying benefits. With the help of MetLife, she also applied for and obtained disability payments from the Social Security Administration.
After two years, the MetLife policy required a new assessment of whether Glenn could perform any job or was still totally disabled. Her physician had repeatedly verified the severity of her condition, but at one point he checked a box on an evaluation form indicating that Glenn was able to work in a “sedentary physical exertion level occupation.”
Three months later, contrary to the checked box, Glenn’s physician again stated that he did not believe she could handle any kind of stress at work.
In evaluating Glenn’s disability claim, MetLife focused on the checked box and decided to stop making disability payments to her.
Glenn challenged the decision and eventually took MetLife to court.
In siding with Glenn, the Sixth Circuit said MetLife cherry-picked certain aspects of Glenn’s medical records, while ignoring others. This selective review, combined with MetLife’s conflict of interest in both evaluating and paying claims, rendered the decision arbitrary and capricious, the appeals court found.
In affirming the Sixth Circuit, Justice Breyer said: “All of these serious concerns, taken together with some degree of conflicting interests on MetLife’s part, led the court to set aside MetLife’s discretionary decision. We can find nothing improper in the way in which the court conducted its review.”
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They FULL OF ****
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MetLife for disability? Avoid the surgery unless it's life-threatening
The worst company I ever dealt with, never received a call from my claim manager.
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Only care about $$$$$
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They demanded an overpayment, stopped my claim, and lied about it
Metlife over paid me. Stopped my Ltd claim. The overpayment were not done right. They lied and said they deposited money in my account.
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Your decision making process is absurd!
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Answered Questions by Our Lawyers
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Q: Can Metlife reduce my LTD benefit due to SERP payments that were not paid to me (they went directly to FICA taxes)?
A: Jim:If this payment is a form of a retirement or pension payment then it is likely correct for Metlife to of... Read More >
Q: Do I have an option after my appeal is denied?
A: Lauren:If your appeal is denied by MetLife then you have the option to file lawsuit in federal court. Read More >
Q: My daughter died in 2019
A: If your daughter was disabled prior to being terminated then she should have coverage. Read More >
Q: Can I sue Metlife for non payment of approved claim?
A: Unfortunately, the answer is "not liklely." I would assume your MetLife policy is an employer provided policy ... Read More >
Q: How far behind in payments does Metlife have to be to take legal action?
A: Make sure you put all of your requests in writing so there is a record should you end up in court. It’s best... Read More >
Q: Does Metlife pay Disability payments ahead? Example: December payment is for January.
A: Peg, most disability insurers pay monthly disability benefits in arrears, in other words, payments are made fo... Read More >
Q: Would any new disabling conditions be considered by Metlife when considering whether or not to continue my benefits?
A: The change in diagnosis will likely lead to denial so please explain the situation to your treating doctor. Me... Read More >
Q: MetLife: Mental Health and Physical Disabilities
A: If you have physical disabilities that prevent you from working then you have options to get around the mental... Read More >
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Our goal is to get your application for disability insurance benefits approved. Applying for disability insurance benefits can be a difficult process and the information you provide is critical. Most disability insurance companies look at your application in hopes of finding a reason to deny your claim. Your disability company will ask you to complete numerous forms, interview you, request lots of information, speak with your doctors and possibly request to have you examined by their hired gun doctor.
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Our attorneys have been able to either get our clients paid monthly disability benefits or obtain a one-time lump-sum settlement in more than 98% of our cases. Our disability insurance lawyers have seen it all when it comes to disability insurance claims and we know exactly what it takes for your disability claim to be approved.
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Since we represent disability insurance claimants at different stages of a disability insurance claim we offer a variety of different fee options. We understand that claimants living on disability insurance benefits have a limited source of income; therefore we always try to work with the claimant to make our attorney fees as affordable as possible.
The three available fee options are a contingency fee agreement (no attorney fee or cost unless we make a recovery), hourly fee or fixed flat rate.
In every case we provide each client with a written fee agreement detailing the terms and conditions. We always offer a free initial phone consultation and we appreciate the opportunity to work with you in obtaining payment of your disability insurance benefits.
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No. For purposes of efficiency and to reduce expenses for our clients we have found that 99% of our clients prefer to communicate via phone, email, fax, or video conferencing sessions. If you prefer an initial in-person meeting please let us know. A disability company will never require you to come to their office and similarly we are set up so that we handle your entire claim without the need for you to come to our office.
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