Eleventh Circuit Finds MetLife Unreasonably Terminated Long Term Disability Benefits of Georgia Man Suffering From Chronic Back Pain
The Eleventh Circuit Court of Appeals finds MetLife had no reasonable basis to terminate Georgia man’s long-term disability benefits. The court concluded that MetLife's termination was not supported by the evidence.
In December of 2001, Mr. Cross became disabled following a second back surgery. Chronic back pain made it impossible for him to continue in his job as a supervisor for Georgia Pacific. No longer able to work, he filed a claim for disability benefits with MetLife.
MetLife approved his benefits effective December 2001. In March of 2004, MetLife terminated Mr. Cross’s benefits claiming he was able to return to work. MetLife based this decision on the following information:
- Surveillance of Mr. Cross coaching his son’s baseball team
- MRI showing no disc herniations
- Medical examination of Mr. Cross performed by Dr. Peach, MetLife’s doctor
- Paper based review completed by Dr. Greenhood, MetLife’s doctor
- Paper based review completed by Dr. Gosline, MetLife’s doctor
- Paper based review completed by Dr. Ito, MetLife’s rehabilitation specialist
On the other hand, evidence supporting Mr. Cross’s continued disability included:
- History of multiple back surgeries, epidural injections, pain medications, and treatment with numerous specialists
- Opinion of Mr. Cross’s neurosurgeon that he continues to experience pain post-surgery
- Opinion of Mr. Cross’s pain management specialist that he is currently disabled from any gainful employment and will likely remain disabled for the rest of his life
- Award of social security disability benefits
- History of anxiety and depression
The Court’s Review of Mr. Cross’ Claim
The court found MetLife was wrong in terminating Mr. Cross’s LTD benefits for the following reasons:
- MetLife unreasonably relied on surveillance which provided mere “snapshots” of Mr. Cross’s activities over the course of several days.
- MetLife unreasonably relied on Dr. Peach’s medical examination as he was unable to validly assess Mr. Cross’s actual limitations.
- MetLife unreasonably relied on Dr. Gosline’s report which only addressed Mr. Cross’s psychiatric conditions and not his physical limitations.
- MetLife unreasonably relied on Dr. Greenhold’s opinion that Mr. Cross could do light work without addressing Mr. Cross’s abilities and limitations.
- MetLife unreasonably relied on Dr. Ito’s opinion that Mr. Cross could tolerate sedentary to light activities with accommodations without determining which accommodations were feasible.
The court ultimately ruled in Mr. Cross’s favor, concluding MetLife arbitrarily discounted ample evidence supporting disability.
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