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Employee gets another crack at disability benefits for back injury

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A Citigroup Inc. employee who was denied long-term disability benefits for a back injury for which he refused to seek treatment may be entitled to those benefits, an appellate court found.

The 3rd U.S. Circuit Court of Appeals in Philadelphia on Thursday vacated and remanded the judgment in favor of Citigroup by the U.S. District Court for the District of New Jersey and its claims administrator, Metropolitan Life Insurance Co., which denied the employee benefits after he failed to provide evidence that he could not work.

Frank Reed, a just-hired Citigroup financial adviser, fell and injured his back at a company-related event in 2008. Claiming he could no longer work, Mr. Reed, submitted a claim for salary continuation benefits, which he received. He later claimed long-term disability, which the plan administrator, MetLife, also approved for the maximum period under Citigroup’s plan, according to court documents in the case, Frank Reed v. Citigroup Inc. and Metropolitan Life Insurance Co.

But though Mr. Reed visited several doctors in 2008 and 2009, he never followed through on a treatment plan. After an independent physician review of Mr. Reed’s case finding that he did not follow doctor recommendations even though he had ample time, MetLife ultimately terminated Mr. Reed’s long-term disability benefits in November 2009, stating there was no documentation supporting Mr. Reed’s “level of functioning” and failure to obtain treatment required by the plan.

The employee appealed the decision, filing a complaint under the Employee Retirement Income Security Act, and the District Court affirmed Citigroup’s motion for summary judgment while denying Mr. Reed’s motion.

A three-judge panel of the 3rd Circuit unanimously found that the District Court’s summary judgment was not appropriate.

“We conclude that there are genuine issues of material fact and that it is not clear from the current record whether MetLife’s decision was arbitrary and capricious,” the opinion reads.

The appellate court stated in the opinion that the District Court “erred to the extent it concluded that MetLife’s termination decision was valid based on Reed’s failure to be under ‘appropriate care and treatment.’”

Instead, the District Court should have based its decision on whether it was “arbitrary and capricious” of MetLife to conclude that the medical information provided did not support Mr. Reed’s claims that he could no longer perform full-time work, even though MetLife had previously found that the documentation submitted was substantial enough to approve the benefits.

Mr. Reed also made claims for breach of fiduciary duty and equitable estoppel and waiver. The appellate court affirmed the District Court’s summary judgment on those claims.

“For the foregoing reasons, we will vacate the District Court’s order in part, affirm in part, and remand for further proceedings,” the opinion states.

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