Citing the high court’s decision in Metropolitan Life Insurance Company vs. Glenn, the appellate court noted that MetLife’s conflict as both payer and administrator of the LTD plan in the present case is “but one factor among many that a reviewing judge must take into account” and should not itself lead to “special burden-of-proof rules, or other special procedural or evidentiary rules.” (See 4th Circuit Takes New Approach on Conflict of Interest Case) The appellate court said the district court correctly concluded that MetLife’s initial finding of disability, its payment of LTD benefits for almost two years, and its referral of its termination decision to two independent doctors suggests that MetLife was not inherently biased in making its decision.
However, the court agreed with the U.S. District Court for the Eastern District of North Carolina’s decision that MetLife’s decision to terminate Gloria Williams’ LTD benefits is not supported by substantial evidence. “In the face of overwhelming evidence concerning Williams’ continued pain and difficulty in attempting to use her hands and wrists, MetLife relied on a scintilla of evidence that did not directly address these problems,” the court said.
In affirming the award of attorneys’ fees, the 4th Circuit cited a Supreme Court decision (see U.S. High Court Sets New ERISA Attorneys’ Fees Standard) that expressly rejected the requirement that a party must be a “prevailing party” in the case to be eligible for an attorneys’ fees award in an Employee Retirement Income Security Act (ERISA) case, but said the party only must have achieved “some degree of success on the merits.” The appellate court noted that Williams’ degree of success was very high, as shown by the district court’s grant of Williams’ motion for summary judgment and the district court’s holding that Williams was entitled to long-term disability benefits.
After years on disability for surgeries to address carpal tunnel and other hand problems, MetLife terminated Williams’ long-term disability benefits based on a doctor’s report relating Williams’ statements that she was having “good and bad days,” and that her pain averaged a three on a ten-point scale. The report did not specifically address Williams’ hand and wrist pain, nor did the report conclude that Williams was able to return to work.
Williams exercised her appeal rights under the plan and submitted additional medical evaluations in support of her appeal. MetLife referred Williams’ file to doctors of its own who concluded the information in Williams’ file did not support an inability to perform her job duties, so MetLife upheld its decision terminating Williams’ long-term disability benefits.
Williams filed a lawsuit, and the district court found that MetLife’s review focused on the medical records relating to Williams’ neck and shoulder trouble, while failing to address in substance Williams’ well-documented problems with her hands and wrists. The court awarded Williams long-term disability benefits as well as attorneys’ fees in the amount of $18,240.00 and $350.00 in costs.
The case is Williams v. Metropolitan Life Insurance Co., 4th Cir., No. 09-1025.