Schwartz
Schwartz v. Metropolitan Life Insurance
Opinion
Lead Opinion
MEMORANDUM **
Mark Schwartz sued Metropolitan Life Insurance Company (“Met Life”) under 29 U.S.C. § 1132 (a)(1)(B), claiming that Met Life’s decision to deny him long term disability benefits was erroneous. The district court reviewed Met Life’s decision for abuse of discretion and granted summary judgment to Met Life. We conclude that the district court applied the wrong standard of review to Met Life’s decision and, accordingly, we reverse and remand with instructions to apply a de novo standard of review.
Denials of benefits that are challenged under 29 U.S.C. § 1132 (a)(1)(B) are reviewed de novo by the federal courts unless the benefit plan confers upon the administrator discretionary authority to determine eligibility for benefits or to construe the terms of the plan. Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 115 , 109 S.Ct. 948 , 103 L.Ed.2d 80 (1989). When an administrator has discretionary authority, federal courts apply a more deferential abuse of discretion or arbitrary and capricious standard of review to the administrator’s decision. See, e.g., Sandy v. Reliance Standard Life Ins. Co., 222 F.3d 1202, 1204 (9th Cir.2000). Benefit plans rarely confer…