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McQUISTIAN v. METROPOLITAN LIFE INSURANCE COMPANY

October 13, 2005.

KERRY A. McQUISTIAN, Plaintiff,
v.
METROPOLITAN LIFE INSURANCE COMPANY, Defendant.



The opinion of the court was delivered by: GARY LANCASTER, District Judge

MEMORANDUM

Before the court are the parties' cross motions for summary judgment. This is a claim for disability benefits under ERISA, 29 U.S.C. § 1132(a) (1) (B). Plaintiff appeals defendant's denial of long term disability benefits, arguing that defendant acted in an "arbitrary and capricious" manner and abused its discretion by denying plaintiff's claim. Defendant claims to have acted within its discretionary authority to determine eligibility for benefits and to construe the terms of the long term disability plan at issue.

Both parties have filed motions for summary judgment under Fed.R.Civ.P. 56(c), arguing that there are no issues of material fact. Plaintiff claims that defendant, as both fiduciary and administrator of the long term disability plan, abused its discretion in denying plaintiff's claim for extended disability benefits. To the contrary, defendant argues that it is entitled to summary judgement because its interpretation of the long term disability plan and the terms therein was reasonable.

  For the following reasons, defendant's motion for summary judgment will be GRANTED and plaintiff's motion for summary judgment will be DENIED.

  I. BACKGROUND

  Unless otherwise indicated, the following material facts are undisputed.

  Plaintiff is a former employee of Praxair, Inc. As a result of his employment, he was a participant in Praxair's long-term disability plan (the "Plan"). Defendant Met Life served as the claims administrator for the Plan.

  Plaintiff began his employment with Praxair in 1991 as a tool and die maker. He stopped working on June 14, 1998 due to a diagnosis of major depressive disorder. On December 16, 1998, defendant approved plaintiff's application for benefits. According to the Plan, benefits for disability due to mental illness are limited to 24 months unless the participant is confined to a legally certified hospital or continues to be a participant in an "approved managed mental health care program." On October 10, 2000, defendant notified plaintiff that because he was not a participant in a managed mental health care program, his benefits would expire on December 15, 2000. In an effort to keep his benefits from expiring, on December 4, 2000, plaintiff submitted a psychiatric evaluation and five appointment slips from his treating psychiatrist as proof that he was being treated through Allegheny East Mental Health/Mental Retardation. On January 2, 2001, defendant notified plaintiff that the documents plaintiff supplied failed to demonstrate that he was a participant in an approved managed mental health care program. Plaintiff then brought this ERISA action to challenge the Administrator's decision under 29 U.S.C. § 1132(a) (1) (B), which allows an ERISA plan participant to bring a civil action to recover benefits under the terms of the Plan.

  II. STANDARD OF REVIEW

  A. The Summary Judgment Standard

  Fed.R.Civ.P. 56(c) provides that summary judgment may be granted if, drawing all inferences in favor of the non-moving party, "the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law." Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247 (1986) (internal quotation marks omitted). Further, because the instant case is a review of an administrative decision, it is appropriate for summary disposition. Couzens v. Equitable Life Assurance Society of the United States, No. Civ. A. 98-527, 1998 WL 695425 (E.D. Pa. Oct. 2, 2005).

  The mere existence of some factual dispute between the parties will not defeat an otherwise properly supported motion for summary judgment. Anderson, 477 U.S. at 247-48. A dispute over those facts that might affect the outcome of the suit under the governing substantive law, i.e., the material facts, however, will preclude the entry of summary judgment. Id. at 248. Similarly, summary judgment is improper so long as the dispute over the material facts is genuine. In determining whether the dispute is genuine, the court's function is not to weigh the evidence or to determine the truth of the matter, but only to determine whether the evidence of record is such that a reasonable jury could return a verdict for the nonmoving party. Id.

  B. The Arbitrary and Capricious Standard Under ERISA

  When, as here, a plan administrator has the discretionary power to construe the terms of a plan or to determine who is eligible for benefits, the court will review the administrator's decision according to an "arbitrary and capricious" standard. See Stoetzner v. United States Steel Corp., 897 F.2d 115, 119 (3d Cir. 1990). Under the arbitrary and capricious standard, the court will overturn an administrator's decision only if it is "`without reason, unsupported by substantial evidence or erroneous as a matter of law.'" Abnathya v. Hoffmann-La Roche, Inc., 2 F.3d 40, 45 (3d Cir. 1993) (citations omitted). The court's review is narrow; "`the court is not free to substitute its own judgment for that of the [administrator] in determining eligibility for plan benefits.'" Id. (citation omitted). Therefore, the court will not disturb an administrator's interpretation "if reasonable." See Firestone Tire and Rubber Co. v. Bruch, 489 U.S. 101, 111 (1989). The court will accept that an administrator acted reasonably if the administrator ...


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