Prichard v. Metropolitan Life Insurance

Matthew Prichard appeals from the district court’s judgment affirming Metropolitan Life Insurance Company’s (MetLife) decision to deny him long-term disability benefits under the long term disability plan of his employer, IBM. We have jurisdiction over this appeal pursuant to 28 U.S.C. § 1291 . Prichard argues that the district court erred in reviewing MetLife’s decision for an abuse of discretion, rather than de novo. He argues in the alternative that even if the district court was correct in using the abuse of discretion standard, MetLife abused its discretion here. We hold that the district court should have reviewed MetLife’s decision de novo, not for an abuse of discretion. We therefore vacate and remand for the district court to review MetLife’s denial of benefits de novo.

I.

Prichard was covered by IBM’s Long Term Disability Plan (Plan), which was insured and administered by MetLife. In January 2007, Prichard applied to MetLife for long term disability benefits under the Plan. MetLife approved Prichard’s claim based on psychiatric disability and applied a retroactive start date of July 20, 2006. However, MetLife determined that Prichard’s benefits period would be…