Mr. Furey and his Claim for Long-Term Disability (“LTD”) Benefits
After the plaintiff, Mr. Furey, began experiencing fatigue in 2014, he was diagnosed with hemochromatosis and started phlebotomy treatment. Further tests and lab work confirmed that Mr. Furey also suffered from livery dysfunction and low testosterone. In February 2015, Mr. Furey began having problems with social anxiety and depressed mood and stopped working at the end of the month.
Mr. Furey filed a claim for LTD benefits, in which he listed his disabling conditions as depression, anxiety, hemochromatosis, and low testosterone. MetLife approved his claim but, just two years later, then determined that Mr. Furey was no longer entitled to benefits. In its denial letter, MetLife notified Mr. Furey for the first time that his benefits were limited to 24 months under the policy because his disability “is caused by his mental health conditions.”
Twice, Mr. Furey appealed the termination of his LTD benefits and argued that MetLife failed to consider whether he was also disabled due to his physical condition of hemochromatosis. In support of his appeal, Mr. Furey submitted additional evidence including medical records, letters from his doctors, sworn declarations, and a Cardiopulmonary Exercise Test (CPET).
Adopting the opinion of the two doctors it hired to review Mr. Furey’s file, MetLife denied his appeals because “the medical information on file does not support functional limitations … which would prevent him from performing his sedentary job or any occupation due to a physical condition or combination of physical conditions.” Mr. Furey then filed a lawsuit seeking to recover past due disability payments pursuant to the Employee Retirement Income Security Act (“ERISA”).
The Court’s Decision
Upon reviewing the parties’ arguments and evidence, the court found that:
- A claimant’s reliable evidence must be credited and there was nothing in the record suggesting that the opinions of Mr. Furey’s treating physicians were not reliable;
- The opinions of Mr. Furey’s physicians were more reliable on the subject and cause of his functioning because MetLife’s doctors never met or personally examined him; and
- MetLife offered no evidence at all to support its determination that only Mr. Furey’s mental health conditions result in disabling functional limitations.
Reversing MetLife’s decision to terminate Mr. Furey’s benefits, the court held that the mental health limitation did not apply because his physical medical conditions were independently disabling.
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