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Jessie Rogers v. Metropolitan Life Ins. Co

May 15, 2013

JESSIE ROGERS,
PLAINTIFF
v.
METROPOLITAN LIFE INS. CO.,
DEFENDANT



The opinion of the court was delivered by: James K. Bredar United States District Judge

MEMORANDUM

I. Background

Plaintiff Jessie Rogers brought this action pursuant to the Employee Retirement Income Security Act ("ERISA"), 29 U.S.C. § 1001 et seq., claiming that she was wrongly denied disability insurance benefits under a policy issued by Defendant Metropolitan Life Insurance Company ("MetLife") to her former employer, Greenhorne & O'Mara, Incorporated. (Compl., ECF No. 1.) The parties have filed cross-motions for summary judgment, which have been thoroughly briefed. (ECF Nos. 26, 27, 30, 31.) No hearing is necessary. Local Rule 105.6 (D. Md. 2011). Defendant's motion will be granted, and Plaintiff's motion will be denied.

II. Standard of Review

Where a benefits plan gives discretion to the administrator to interpret the policy and determine a claimant's eligibility for benefits, as is true in this case, judicial review is limited to the issue of whether the administrator's determination constitutes an abuse of discretion. Metropolitan Life Ins. Co. v. Glenn, 554 U.S. 105, 111 (2008). Even if the reviewing court would have reached a different conclusion, the administrator's determination stands undisturbed as long as it is reasonable. Fortier v. Principal Life Ins. Co., 666 F.3d 231, 235 (4th Cir. 2012). Factors that may be considered by a court in evaluating the reasonableness of the administrator's decision include the following:

(1) the language of the plan; (2) the purposes and goals of the plan; (3) the adequacy of the materials considered to make the decision and the degree to which they support it; (4) whether the fiduciary's interpretation was consistent with other provisions in the plan and with earlier interpretations of the plan;

(5) whether the decisionmaking process was reasoned and principled; (6) whether the decision was consistent with the procedural and substantive requirements of ERISA; (7) any external standard relevant to the exercise of discretion; and

(8) the fiduciary's motives and any conflict of interest it may have.

Booth v. Wal--Mart Stores, Inc. Assocs. Health & Welfare Plan, 201 F.3d 335, 342-43 (4th Cir. 2000), cited in Fortier, 666 F.3d at 235-36. See also Evans v. Eaton Corp. Long Term Disability Plan, 514 F.3d 315, 322 (4th Cir. 2008) ("an administrator's decision is reasonable 'if it is the result of a deliberate, principled reasoning process and if it is supported by substantial evidence'" (citation omitted)).

III. Undisputed Facts

Rogers began working in October 2000 as an Employee Services Specialist with Greenhorne & O'Mara. Her job was classified as sedentary. Her last day of work was February 6, 2008. (ML000814--815.)*fn1 On February 7, 2008, she underwent surgery for her degenerative lumbar disk disorder and received an L5-S1 laminectomy and fusion. (ML000739, ML000814--816.) She was approved for short-term disability benefits from February 7, 2008, to May 7, 2008, under the policy issued and administered by MetLife. (ML000697.) On April 17, 2008, she filed an application for long-term disability ("LTD") benefits. (ML000680--81.) She stated she had ongoing back and leg pain both before and after the surgery; the records indicate she had complications from the surgery. (ML000680, ML000808.)

She was approved for LTD benefits on April 22, 2008, effective May 7, 2008. (ML000659.) The letter of approval notified Rogers that she would continue to receive LTD benefits as long as she continued to meet the plan's definition of disability and to submit medical information to MetLife for review. (Id.) MetLife further notified her it would request medical information at reasonable intervals, indicating it would be Rogers's responsibility to ensure that her medical providers were submitting the information. (Id.) The letter also recited the applicable definition of disability, quoted here in pertinent part:

[T]he definition of Disabled or Disability means that . . ., due to Sickness, or as a direct result of accidental injury:

 You are receiving Appropriate Care and Treatment and complying with the requirements of such treatment; and

 You are unable to earn:  During the Elimination Period and the next 24 months of Sickness or accidental injury, more than 80% of Your Predisability Earnings at your Own Occupation from any employer in your local Economy. (ML000659.) After the 24-month period mentioned in the letter, Rogers would be subject to a different definition of disability, as set forth in the MetLife plan:

 You are unable to earn:  [A]fter such period, more than 80% of your Predisability Earnings from any employer in Your Local Economy at any gainful occupation for which You are reasonably qualified taking into account Your training, ...


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