Medina v. Metropolitan Life Insurance Co.

Plaintiff Luis Medina appeals from the district court’s entry of summary judgment in favor of defendant Metropolitan Life Insurance Company (“MetLife”). Medina contends that MetLife violated the Employment Retirement Security Act of 1974 (“ERISA”), 29 U.S.C. §*1001 et seq., by using an arbitrary and capricious procedure in terminating his short-term disability benefits and refusing to grant him long-term disability benefits. He also seeks monetary sanctions against MetLife for an alleged breach of its disclosure obligations under 29 U.S.C. § 1132. The district court found no violation in either of the benefits determinations. We affirm.

Medina worked as a maintenance technician for Abbott Laboratories, Inc. in Puerto Rico. As an Abbott employee, he participated in a disability insurance plan administered by Metlife that provided both short-term and long-term disability benefits (“the Plan”). In June 2006, Medina ceased work due to obstructive sleep apnea and high blood pressure. Shortly thereafter, he submitted a claim for short-term disability benefits under the Plan. His treating physician, Dr. Hector Stella, provided MetLife a diagnostic report. On August 1, 2006, MetLife informed Medina that it would grant him short-term disability benefits for a limited period, but would require additional documentation before any further benefits would be awarded. Dr. Stella submitted a second evaluation on August 21, 2006 containing further diagnoses but little in the way of specific test results.