Posted October 17th, 2013 in Top Stories
Nilan Johnson Lewis Helps Metropolitan Life Insurance Company Win Motion for Summary Judgment
Nilan Johnson Lewis attorney William D. Hittler and the ERISA team’s work for Metropolitan Life Insurance Company (MetLife) earned the company a victory at the United States District Court for the District of Minnesota on October 9, when the court granted MetLife’s motion for summary judgment. At issue in the case Konrad v. Metropolitan Life Insurance Company was the insurer’s adverse determination of a claim for benefits based upon interpretation of the “brain damage” provision of the accidental death and dismemberment insurance benefit plan and whether MetLife’s determination was an abuse of discretion under the federal ERISA statute.
In this case, the plaintiff was severely injured when the motorcycle he was riding collided with a mattress that fell off a vehicle. He suffered from head trauma and other injuries. Though his psychologist dubbed his significant recovery “remarkable” and the man had regained independence in his daily routine, he still struggled with significant residual functional difficulties and was deemed unlikely to work in a similar position in the future. MetLife, which administered the man’s employer-sponsored benefit plan, determined that the man did not meet the plan’s definition of “brain damage” because he did not demonstrate that his injury caused “the complete inability to perform all the substantial and material functions and activities normal to everyday life, and upheld that determination on appeal. The plaintiff, through his guardian ad litem, subsequently brought legal action seeking review of MetLife’s denial of benefits.
The court concluded that MetLife did not abuse its discretion, and also applied the five-factor Finley test as set forth in Finley v. Special Agents Mutual Benefit Association, Inc. The Finley factors are: (1) whether the administrator’s interpretation is contrary to the clear language of the plan; (2) whether the interpretation conflicts with the substantive or procedural requirements of ERISA; (3) whether the interpretation renders any language in the plan meaningless or internally inconsistent; (4) whether the interpretation is consistent with the goals of the plan; and (5) whether the administrator has consistently followed the interpretation. Although the Court found that the plan provision at issue was capable of two interpretations consistent with the terms of the plan, but nonetheless concluded that MetLife’s interpretation was reasonable.