Court Asks Administration To Discuss Disability Case

The company cut off Glenn’s benefits after an independent consultant suggested that Glenn might be able to handle a sedentary job on a trial basis.

Glenn sued for reinstatement of benefits in the U.S. District Court in Columbus, Ohio, in 2003.

The court ruled in MetLife’s favor, noting that the LTD policy included a clause giving MetLife discretion over benefits determinations.

A panel of 3 judges from the 6th U.S. Circuit Court of Appeals decided in September 2006 to overturn the lower-court ruling.

Although courts can overturn determinations involving LTD plans with discretionary clauses only when the determinations are “arbitrary and capricious,” the “arbitrary-and-capricious standard…does not require us merely to rubber stamp the administrator’s decision,” Judge Martha Craig Daughtrey wrote in the opinion explaining the court’s decision.

In the MetLife case, MetLife may have had a conflict of interest because it acted both as the LTD insurer and the LTD plan administrator, and it may not have given sufficient consideration to the Social Security Administration’s determination that Glenn was totally disabled, Daughtrey wrote.

The 6th Circuit holding on the conflict-of-interest issue conflicts with holdings in 2 other circuits, and the holding on the lack of weight apparently given to the SSA determination conflicts with holdings in 6 other circuits, according to Public Citizen, Washington.