Carol Hunt v. Metropolitan Life Insurance Company

Carol Hunt worked as a buyer for International Business Machines Corporation
(IBM) from January 1993 until March 2001, when she went on approved leave
because of problems with concentration, fatigue, and sleep arising from her restlesslegs
syndrome (RLS).1 After she was denied long-term disability (LTD) benefits by
IBM's plan administrator, Metropolitan Life Insurance Company (MetLife), Hunt
brought suit under the Employment Retirement Income Security Act (ERISA). The
district court2 granted summary judgment to the defendants, and Hunt appeals.
IBM's Plan (Plan) gives MetLife discretionary authority in processing claims,
and provides for LTD benefits for "totally disabled" participants, defined as follows:

[T]otally disabled means that during the first 12 months after you
complete the waiting period, you cannot perform the important duties of
your regular occupation with IBM because of a sickness or injury. After
expiration of that 12 month period, totally disabled means that, because
of a sickness or injury, you cannot perform the important duties of your
occupation or of any other gainful occupation for which you are
reasonably fit by your education, training or experience. You must be
under the appropriate care and treatment of a doctor on a continuing
basis. At your own expense, proof of disability, satisfactory to
Metropolitan, must be submitted to Metropolitan.
(App. at 15). Because the plan gives MetLife discretion to determine eligibility, we
review the administrator's decision for abuse of discretion. See Firestone Tire &
Rubber Co. v. Bruch, 489 U.S. 101, 111 (1989); King v. Hartford Life & Accident Ins.
Co., 414 F.3d 994, 998-99 (8th Cir. 2005) (en banc). Under this standard of review,
we consider whether the administrator adopted a "reasonable interpretation" of
uncertain terms in the plan, and whether the administrator's decision was supported
by substantial evidence, i.e., "such relevant evidence as a reasonable mind might
accept as adequate to support a conclusion." King, 414 F.3d at 999 (internal
quotations omitted).

Having carefully reviewed the record, we conclude that MetLife did not abuse
its discretion in denying Hunt LTD benefits. Although we are mindful of Hunt's selfreported
complaints of extreme tiredness, fatigue, mental confusion, loss of memory,
anxiety attacks, and depression, and the opinion of Hunt's treating physician that RLS
has rendered her totally disabled, MetLife was nevertheless entitled to rely on the
opinions of two reviewing physicians who gave contrary opinions. The "treating
physician rule" – that opinions of treating physicians must be accorded special weight
– does not apply to disability benefit determinations under plans governed by ERISA.
See Black & Decker Disability Plan v. Nord, 538 U.S. 822, 825 (2003).

In this case, MetLife first sent Hunt's records to Dr. Joseph Jares, a neurologist,
in March 2002. Dr. Jares opined that "Ms. Hunt is capable of working at least in a
sedentary position." (App. at 161). He also suggested, however, that Ms. Hunt "have
a sleep study and neuropsychological testing to objectively diagnos[e] her
complaints." (App. at 162). Hunt then provided MetLife with a sleep study
performed by her treating physician in April 2002, which revealed, according to the
physician, "very little sleep and leg movements suggestive of restless leg syndrome
but no periodic limb movement." (App. at 188-89). In May 2002, MetLife submitted
Hunt's records to Dr. J. W. Rodgers, who is board-certified in internal and pulmonary
medicine. Dr. Rodgers concluded there was "little doubt that this patient has restless
leg syndrome." (App. at 193). He noted that the sleep study had been conducted, but
that the neuropsychological testing recommended by Dr. Jares in March "still remains
to be done." (Id.). Dr. Rodgers concluded that "[w]hat is in question is the effect of
restless leg syndrome on this patient's neuropsychological profile and cognitive
capabilities." He recommended that "until we have objective evidence of impairment
in this functional realm, we cannot consider the patient to be impaired on the basis
of evidence in our file." (Id.).

In view of the conflicting opinions offered by Hunt's treating physician and the
reviewing physicians, MetLife's decision to deny Hunt's claim based on the opinions of Dr. Jares and Dr. Rodgers was not an abuse of discretion. We have held that an
administrator may deny benefits based on a lack of objective evidence of disability.
McGee v. Reliance Standard Life Ins. Co., 360 F.3d 921, 924-25 (8th Cir. 2004). In
this case, Dr. Jares suggested that Hunt undergo neuropsychological testing as a
means "to objectively document" her complaints, and the absence of objective
evidence concerning Hunt's "neuropsychological profile and cognitive capabilities"
was the basis for Dr. Rodgers's opinion that she was not disabled. We believe this
is a conclusion that a reasonable mind might accept as adequate on this record. See
King, 414 F.3d at 999.