November 6, 2009
Previously published on October 2009
Charles McDonald v. Metropolitan Life Insurance Company, Civil No. JFM-08-02063 (D. Md. October 20, 2009)
Charles McDonald ("McDonald"), former Constellation Energy Group employee, claimed that he was unable to perform his duties as supervisor of distributions operations, due to tremors in his left arm, which were later determined to be related to McDonald's emotional state. Specifically, McDonald's primary care physician found that McDonald's "psychogenic tremors" were evidence of depression and agitation. McDonald ceased his employment and sought long-term disability benefits from his employer's long-term disability plan ("the Plan"). Metropolitan Life Insurance Company ("MetLife") was the Plan's Claim Administrator.
MetLife approved McDonald's long-term disability claim. As part of the grant of benefits, McDonald was under an ongoing obligation to continue to provide proof of his disability in order to continue receiving benefits. McDonald complied with MetLife's requirements and continuously sent his medical records to MetLife.
MetLife referred McDonald's medical records for review by an independent physician consultant who determined that McDonald's disability did not prevent him from performing his job. Thereafter, MetLife terminated McDonald's receipt of long-term disability benefits. McDonald appealed MetLife's decision to terminate his benefits. MetLife then referred McDonald's medical records to two additional independent physician consultants for review; both consultants determined that McDonald was able to perform his job. None of the independent consultants ever examined McDonald, but rather based their assessments on review of his medical records. MetLife upheld its decision to terminate McDonald's benefits.
McDonald filed suit against MetLife in the United States District Court for the District of Maryland, pursuant to Section 502(a)(1)(B) of the Employee Retirement Income Security Act of 1974, 29 U.S.C. § 1001 et seq. ("ERISA"). ERISA provides individuals with a right to bring a civil action against an insurance company to recover benefits due under the terms of an insurance plan, to enforce their rights under the terms of a plan, or to clarify their rights to future benefits under the terms of the plan. 29 U.S.C. § 1132(a)(1)(B). McDonald alleged that MetLife abused its discretion by terminating his long-term disability benefits without conducting a full and fair review.
The Plan gave MetLife discretion to construe the terms of the Plan; therefore, the U.S. District Court for the District of Maryland reviewed MetLife's decision to terminate McDonald's benefits, under the "abuse of discretion standard." In other words, MetLife's decision to terminate McDonald's benefits would only be upheld by the Court if the Court found that the decision was reasonable.
The Court, in granting MetLife's Motion for Summary Judgment, held that the record indicated that MetLife's decision to terminate benefits "resulted from a principled decision-making process." MetLife reviewed McDonald's records and sought review from three independent consultants. Although MetLife had initially awarded benefits to McDonald, it was entitled to continue evaluating his condition after the initial award. The Court further held that MetLife was not required to adopt the diagnosis of McDonald's primary care physician over the decision of the independent consultant. "It was not an abuse of discretion for MetLife to rely on its three consultant physicians' reports without explicitly explaining its decision to do so."
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