Judge v. Metro Life Ins. Co.

On March 25, 2013, the Sixth Circuit issued the ERISA opinion of Judge v. Metro Life Ins. Co., whereby the appeals court affirmed a summary judgment in favor of the plan administrator on several different issues that an ERISA plaintiff confronts in trying to receive benefits. The court found that the plaintiff was not totally and permanently disabled under the terms of the Plan, a very restrictive definition for disabled. The court further found that MetLife could rely on a file review of a paid nurse instead of having the plaintiff sent out for an Independent Medical Exam (“IME”). Finally, the court did not find that MetLife had a conflict of interest that affected its denial decision, even though it both had to evaluate and pay the claims. This decision reinforces the several hurdles that ERISA presents for a person seeking long term disability benefits.