In Stupar v. Metropolitan Life Insurance Company (MetLife), plaintiff, an icer with the Kroger Company, received 24 months of long term disability benefits due to her diagnoses of post-traumatic stress disorder (PTSD), major depression, panic and anxiety disorder. At the end of the two-year period, MetLife terminated her benefits on the grounds that she was limited to 24 months of benefits under the Mental or Nervous Disorders clause of the policy. She objected, exhausted her administrative remedies, then filed this ERISA lawsuit.
Plaintiff Failed to Present Any Evidence of a Physical Cause of Her Mental Conditions
After donating a kidney to her husband in 2006, plaintiff Hasnija Stupar suffered from numerous medical problems. Finally, in 2011, she was diagnosed with the above stated mental disorders and awarded 24 months of long term disability benefits. According to the terms of the policy, at the end of the 24 months, the only way she could qualify for long term disability is if she could provide medical documentation of a physical cause of her ailments.
The District Court analyzed hundreds of pages of Stupar’s medical reports. The Court noted that, even though she was evaluated and treated by numerous physicians, her condition remained the same from the time she was first diagnosed through the completion of the legal proceedings. Peer reviews by MetLife’s physicians found no independent medical reason for Stupar’s numerous psychological problems. Some physician reports noted she had a right-hand tremor, but treating physicians and an independent physician consultant (IPC) concluded that Stupar’s “tremors were caused by Plaintiff’s anxiety.”
The Court noted that MetLife “expressly requested additional information pertaining to Plaintiff’s tremors, but no such information was available given Plaintiffs lack of treatment and testing therefor.” Accordingly, the Court concluded that, “Based on the available evidence, it was not wrong for [MetLife] to infer that the tremors were likely mental in nature.”
MetLife Properly Denied Plaintiff’s Claim for Benefits for Her Alleged Bipolar Disorder
Stupar asserted her mental problems were due to a bipolar disorder which, under the mental limitations clause, might allow her to continue receiving benefits. The Court noted that no evidence of a bipolar disorder had ever been presented to MetLife except for one phrase in one of her numerous medical reports that stated, “Ms. Stupar ‘has a history of… bipolar.’” Since there was no evidence in the record to support Stupar’s assertion that she had a bipolar disorder, “she did not qualify for an exception to the 24-month limitation.”
This case was not handled by our office, but it may help those who suffer from a physical condition as well as a limiting mental disorder to understand the kind of evidence the insurer or Court looks for in evaluating a disability claim. If you have questions about this, or any other aspect of your claim for disability benefits, feel free to contact one of our attorneys at Dell & Schaefer for a free consultation.