Metropolitan Life Insurance Co. won a round in a case over denied disability benefits, despite failing to convince a federal judge that it was entitled to a favorable judicial review standard.
The Barclays Bank PLC computer programmer who sued MetLife for benefits didn’t initially prove that his depression rendered him incapable of earning more than 80 percent of his prior salary, a federal judge ruled March 5. However, the case will move toward trial because it’s unclear whether MetLife acted reasonably in denying the programmer’s subsequent appeal, which included additional information supporting his claim to disability benefits, the judge said.
The case is noteworthy because the standard of judicial review used by the court—which can often determine the outcome of benefit disputes under the Employee Retirement Income Security Act—turned on which page of an insurance booklet contained the special language that would entitle MetLife to a more favorable review standard.
Specifically, the judge reviewed MetLife’s conduct more strictly after finding that the insurer’s discretionary clause—language included in a benefits plan that typically causes courts to defer to an insurer’s decision—wasn’t included in the plan itself. The language was contained in a booklet section called “Additional Information” that appeared after a 44-page certificate of insurance that ended with the sentence “THIS IS THE END OF THE CERTIFICATE,” the judge said.
Despite using a stricter review standard, the judge nevertheless agreed with MetLife’s decision to deny benefits in the first instance. Because it was less clear whether MetLife was correct in denying the programmer’s subsequent appeal, the judge ordered the parties to proceed toward trial.
Judge J. Paul Oetken of the U.S. District Court for the Southern District of New York wrote the decision.
Riemer & Associates LLC represented the programmer. Robinson & Cole LLP represented MetLife.
The case is Sigal v. Metro. Life Ins. Co., 2018 BL 74353, S.D.N.Y., No. 1:16-cv-03397-JPO, order granting and denying summary judgment 3/5/18.
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