Lawyer Commentary LexBlog United States Fourth Circuit Holds ERISA Plaintiff Did Not Demonstrate Disability Due to Non-Limited Condition Under Terms of Disability Policy

Fourth Circuit Holds ERISA Plaintiff Did Not Demonstrate Disability Due to Non-Limited Condition Under Terms of Disability Policy

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In Penland v. Metropolitan Life Insurance Company, No. 24-1772, 2025 WL 1672861 (4th Cir. June 13, 2025), the Fourth Circuit considered Plaintiff Penland’s appeal of the district court’s determination that he did not meet his burden of proving entitlement to long-term disability benefits under his former employer’s plan that is administered by Metropolitan Life Insurance Company. The appellate court ruled against Penland. It acknowledged that Penland experiences significant pain but found that he was not entitled to payment beyond the MetLife policy’s 24-month limitation for disabilities due to conditions including neuromuscular, musculoskeletal, or soft tissue disorders.

MetLife initially approved Penland’s claim for LTD benefits after he ceased working in 2015 due to medical complications. Under his employer’s plan, benefits were contingent on proving an inability to earn more than 80% of predisability income due to sickness or injury. After paying benefits for the initial 24 months, MetLife terminated them in 2021, citing insufficient evidence of non-limited disabling conditions. Penland’s subsequent appeal...

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