MetLife ordered to pay disability benefits beyond 24 months for a claimant with both mental and physical disabilities

Mr. Mark J. Schwartz, an accountant, was insured under his employer’s group disability plan, sponsored by Metropolitan Life Insurance Co. (MetLife), which limits disability benefits for mental illness to 24 months, but to age 65 for a physical disability.

After major heart surgery in 1999, Mr. Schwartz was diagnosed with post bypass anxiety syndrome resulting in elevated blood pressure, dizziness and chest pain. Upon recommendation by his doctor, Mr. Schwartz applied for total disability benefits that year. The application was granted however MetLife concluded the disability was a result of a mental condition, limiting his benefits to 24 months. In 2001, Mr. Schwartz provided additional medical information arguing his disability was physical in nature. After reviewing these records, MetLife’s doctor concluded there were no physical impairments preventing Mr. Schwartz from working. In May 2001, Mr. Schwartz underwent angioplasty and stent surgery. MetLife denied his claim and terminated his benefits in July 2001. Mr. Schwartz sued in U.S. District Court for the District of Arizona seeking reinstatement of benefits under the Employee Retirement Income Security Act (ERISA).

After reviewing the evidence, Judge Mary H. Murguia held that MetLife could have determined Mr. Schwartz’s disability was physical and under estimated the seriousness of Mr. Schwartz’s heart condition. “Plaintiff’s medically documented disability based on a combination of physical and mental impairments warrants the payment of benefits beyond the 24-month period” stated Judge Murguia.

See Mark J. Schwartz v. Metropolitan Life Insurance Co., et al., No. CIV-01-2075, D. Ariz.; 2006 U.S. Dist..