Santana-Diaz v. Metropolitan Life Insurance Co., No. 17-1428 (1st Cir. 2019)Annotate this Case
The First Circuit affirmed district court's grant of judgment in favor of Defendant Metropolitan Life Insurance Co. (MetLife) on Plaintiff's suit challenging the denial of long-term disability (LTD) benefits for Plaintiff under his employee welfare benefit plan (Plan), holding that MetLife's decision to deny LTD benefits to Plaintiff based on physical disability was reasonable and substantially supported by the evidence.
MetLife, the Plan's administrator, denied Plaintiff's claim for benefits, concluding that the medical information provided by Plaintiff did not support the conclusion that Plaintiff was precluded from performing his job due to his medical conditions. After exhausting his administrative remedies, Plaintiff brought suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001-1461. The district court granted judgment on the administrative record to MetLife. The First Circuit affirmed, holding (1) MetLife adequately considered the conditions documented by Plaintiff's physician and physiatrist; (2) MetLife consistently interpreted the Plan; (3) MetLife provided Plaintiff with sufficient information regarding the requisite showing to qualify for LTD benefits; and (4) MetLife did not act in an arbitrary or capricious manner by considering the functional limitations of Plaintiff's condition.