The Disability Application

In Jahn-Derian v. Metropolitan Life Insurance Co., a California Federal Judge disagreed with MetLife’s decision to deny disability benefits due to a lack of objective evidence. First, the court noted that objective evidence is not required since for many medical conditions, such as fibromyalgia, chronic migraines or mental disorders, no objective evidence is medically available. Second, Jahn-Derian provided significant objective evidence to support her claim.

The court did not remand on this issue, but found that, “In sum, the evidence establishes that plaintiff, more likely than not, was disabled within the meaning of the Plan’s terms.” The court ordered MetLife to pay the claimant 24 months of disability based on her inability to perform the tasks of her own occupation. This is a great opinion for disability claimants nationwide.
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In Anderson v. Life Insurance Company of North America (LINA), the Arizona federal court upheld LINA’s denial of short term and long term disability benefits to the plaintiff even though it acknowledged the medical evidence supported her claim to be suffering from numerous medical symptoms. The fact that she suffered from these symptoms did not qualify her for disability benefits when, according to the court, “The record demonstrates that Anderson’s symptoms, at their worst, caused her no greater than mild impairment or slightly below average cognitive performance. In light of that level of impairment, Anderson fails to carry her burden of establishing her inability to continue performing her duties as an account manager.”
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In Leonard v. MetLife Insurance Company, the Ninth Circuit court of appeals upheld the California district court’s dismissal of plaintiff’s ERISA lawsuit against MetLife when she failed to exhaust her administrative remedies or prove there was any applicable exception to excuse her from filing an administrative appeal. The court did not discuss her case or consider the merits of her disability claim, but focused on the proper procedure claimants must file when seeking disability benefits.
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The case of Murphy v. First Unum Life Insurance Company was brought following the administrative appeal which upheld Unum’s termination of plaintiff’s long term disability benefits under the definition of disability that required her to be disabled from “any occupation for which she is reasonably qualified by way of training, education and experience.” The case does not discuss the medical problems of the plaintiff, Marta Murphy, a Lead Medical Assistant at Huntington Hospital, the merits of her claim or reasons why it was denied.
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In Cooper v. Life Ins. Co. of North America, the U.S. Court of Appeals for the Sixth Circuit established precedent for those whose case arises in Kentucky, Michigan, Ohio or Tennessee. After the Plan’s denial of long term disability benefits to the complainant, that was upheld through two administrative appeals and by a Tennessee federal district court, the Sixth Circuit reversed. The court refused to remand the case to the plan administrator for further evaluation since it concluded “that Cooper has clearly established that she is disabled under the Plan.”
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