Seneca v. Metro. Life Ins. Co.

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JASON SENECA v. METROPOLITAN LIFE INSURANCE COMPANY

Civil Action No. 23-00109-BAJ-SDJ

United States District Court, M.D. Louisiana

September 27, 2024

RULING AND ORDER

BRIAN A. JACKSON JUDGE

This is an ERISA case. Before the Court is Plaintiffs Motion For Judgment Under F.R.C.P. 52 On ERISA Administrative Record (Doc. 26, the “Motion”). The Motion requests that the Court reverse Defendant Metropolitan Life Insurance Company's decision to terminate Plaintiffs long-term disability benefits. (Doc. 26). Defendant has filed a Response to Plaintiffs Motion, which the Court construes as a competing motion for judgment brought pursuant to Federal Rule of Civil Procedure 52. (Doc. 27). For reasons provided herein, Plaintiffs Motion will be denied, and judgment shall be entered in favor of Defendant.

I. BACKGROUND

Plaintiff Jason Seneca brought this suit to recover long-term disability benefits that were terminated by Defendant Metropolitan Life Insurance Company as of September 13 2020.^[1] Plaintiff was a member of his employer's disability plan (the “Plan”) prior to becoming disabled. The Plan was at all times governed by the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended.

IL LEGAL STANDARD

a. Rule 52

Plaintiff has requested judgment on the pleadings pursuant to Federal Rule of Civil Procedure 52. (Doc. 26). Rule 52 requires the Court to “find the facts specifically and state its conclusions of law separately.” Fed.R.Civ.P. 52. Courts need not provide findings of fact on “all factual questions that arise in the case,” Koenig v. Aetna Life Ins. Co., No. 4:13-CV-0359, 2015 WL 6554347, at *3 (S.D. Tex. Oct. 29, 2015), nor must courts provide “punctilious detail nor slavish tracing of the claims issue by issue and witness by witness.” Cent. Marine Inc. v. United States, 153 F.3d 225, 231 (5th Cir. 1998) (quoting Burma Navigation Corp. v. Reliant Seahorse M/V, 99 F.3d 652, 656 (5th Cir. 1996)). Rather, Rule 52 is satisfied when the findings “present the reviewer with ‘a clear understanding of the basis for the decision.'” Batchelor v. Life Ins. Co. of N. Am., 504 F.Supp.3d 607, 610 (S.D. Tex. 2020) (quoting Cent. Marine Inc., 153 F.3d at 231). “The findings and conclusions may be stated on the record after the close of the evidence or may appear in an opinion or a memorandum of decision.” Fed.R.Civ.P. 52. Here, the Court's findings of fact and conclusions of law will be provided in this Ruling and Order, and will be based solely on the administrative record and the parties' respective briefs.

b. Standard of Review

The parties agree that ERISA preempts all state law claims related to the Plan. (Doc. 12). The parties also agree that the Plan vested Defendant with discretionary authority to determine eligibility for benefits and to construe and interpret the terms of the Plan. (Id.). The Court therefore reviews Defendant's decision to terminate Plaintiffs long-term disability benefits on an abuse of discretion standard. See Jenkins v. Cleco Power, LLC, 487 F.3d 309, 314 (5th Cir. 2007).

Under this standard, a plan administrator's decision will only be upset if the administrator acted in an “arbitrary or capricious manner in denying benefits.” Id. (citingMatassarin v. Lynch, 174 F.3d 549, 563 (5th Cir. 1999)). A decision is arbitrary when there is no “rational connection between the known facts and the decision or between the found facts and the evidence.” Id. (quoting Bellaire Gen. Hosp. v. Blue Cross Blue Shield of Mich., 97 F.3d 822, 828 (5th Cir. 1996)). Plaintiffs carry the burden of proving an abuse of discretion. Nichols v. Reliance Standard Life Ins. Co., 924 F.3d 802, 813 (5th Cir. 2019). This remains true even when a plaintiff has previously qualified for disability benefits. Batchelor, 504 F.Supp.3d at 610. However, when, as here, the administrator of the Plan and the insurer are one and the same, there is “a conflict of interest,” and the abuse of discretion standard is “somewhere less deferential.” Jenkins, 487 F.3d at 314.

In reviewing a decision to deny or terminate benefits, courts are limited to the administrative record and “may inquire only ‘whether the record adequately supports the administrator's decision.'” Id. (quoting Gooden, 250 F.3d at 333). The administrative record has been provided to the Court. (Docs. 10-1, 10-2, 10-3, 10-4, 10-5, 11-1, and 11-2, hereinafter referred to as the “AR”). The AR exceeds 2,000 pages. (Id.).

Adequate support is found when an administrator's decision is supported by “substantial evidence,” which is “more than a scintilla, less than a preponderance, and is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Anderson v. Cytec Indus., Inc., 619 F.3d 505, 512 (5th Cir. 2010) (quoting Corry v. Liberty Life Assurance Co. of Boston, 499 F.3d 389, 398 (5th Cir. 2007)). Finally, a court's review of a benefits decision need only conclude “that the administrator's decision fall[s] somewhere on a continuum of reasonableness - even if on the low end.” Corry, 499 F.3d at 398 (quoting Vega v. Nat'l Life Ins. Serv., Inc., 188 F.3d 287, 297 (5th Cir. 1999)).

III. FINDINGS OF FACT

a. Initial Determination

Plaintiff began receiving long-term disability benefits on September 13, 2018. (AR at p. 1674-1675). Prior to becoming disabled, Plaintiff was an IT Administrator with HP, Inc. and a member of the long-term disability plan the company held with Defendant. (Id. at pp. 1, 398). Plaintiff suffered from poor health for several years prior to becoming totally disabled. (See, e.g., id. at pp. 827-847). Defendant's approval of Plaintiffs original long-term disability claim did not identify specific limiting conditions, but was issued after Plaintiff was diagnosed with rheumatoid arthritis and neuropathy. (Id. at pp. 1674-1675, 1750). Plaintiffs last day of work with HP, Inc. was March 17, 2018. (Id. at p. 1674). Plaintiffs job duties consisted of maintaining approximately 200 printers and performing occasional onsite repairs of the same. (Id. at p. 918). In the course of his duties, Plaintiff was required to routinely walk, bend, stand, and lift printers. (Id.).

Defendant received several Attending Physician Statements (“APS”) prior to determining that Plaintiff was eligible for long-term disability benefits. (Id. at pp. 1683-1685). Dr. Philip Padgett, Plaintiffs primary care physician, wrote an APS on March 6, 2018, stating that Plaintiff reported to have joint pain and difficulty walking long distances. (Id.). Plaintiff sought Dr. Padgett's care after his responsibilities as an IT Administrator were changed to require Plaintiff to walk six miles daily. (Id. at p. 643). Dr. Padgett opined that Plaintiff could return to work with modifications, but that disability should be determined by a rheumatologist. (Id. at p. 1684).

Enter Dr. Bobby Dupre. On March 7, 2018, Dr. Dupre created the first of his four APS which provided, from a rheumatology perspective, that Plaintiff was disabled by rheumatoid arthritis and neuropathy which caused “joint swelling, pain, [and] tenderness in multiple small joints of hands, wrists, elbows, and feet.” (Id. at pp. 1714-1716). Dr. Dupre predicted Plaintiff would be able to return to work without restriction in approximately six months. (Id.). However, Dr. Dupre also opined that Plaintiff could work with restrictions, such as Plaintiff working from home, not walking more than ten minutes continuously, and not manipulating anything above twenty pounds. (Id. at p. 1715). One month later, Dr. Dupre stated that the cause of Plaintiffs disability was only rheumatoid arthritis, and that Plaintiff could return to work without restriction in six weeks to three months. (Id. at p. 1727). In this APS, Dr. Dupre opined that Plaintiff was unable to perform restricted work. (Id.). On May-23, 2018, Dr. Dupre wrote his third APS. (Id. at p. 1732). He estimated then that Plaintiff could return to work in approximately two to five months. (Id. at p. 1733). Dr. Dupre again altered the identified disabilities to include neuropathy. (Id. at p. 1732). These conclusions were reaffirmed in Dr. Dupre's fourth and final APS, dated July 12, 2018. (Id. At p. 1750).

To treat his rheumatoid arthritis, peripheral neuropathy, and joint pain and swelling, Plaintiff was prescribed methotrexate and Rheumate. (Id. at p. 1735-1738). Plaintiff reported no adverse effects from these medications to Dr. Dupre. (Id. at pp. 1735, 1755). At his last visit with Dr. Dupre, Plaintiff initiated further treatment with Humira. (Id. At p. 1757).

On September 24, 2018, Defendant informed Plaintiff that he would receive long-term disability benefits under the Plan effective September 13, 2018. (Id. at pp. 1674-1675). Plaintiff received these benefits from September 13, 2018, to September 13, 2020. (Id. At pp. 1002-1010).

The Plan defined “totally disabled” as, during the “Elimination Period and the next 24 months,” an inability to perform with reasonable continuity the substantial and material acts necessary to perform an employee's usual occupation in the usual and customary way. (Id. at p. 27). After the Elimination Period elapses, total disability refers to the inability to engage with reasonable continuity in any occupation which the employee could reasonably be expected to perform given the employee's age, education, training, experience, station in life, and physical and mental capacity. (Idi). Those receiving benefits under the Plan are required to periodically send Defendant proof of continued disability. (Id. at p. 37). Failure to do so, or Defendant's determination that payees are no longer disabled, results in a termination of benefits. (Id. at p. 31).

b. Secondary Determination

On January 15, 2020, Defendant no...