Fontaine v. Metropolitan Life Ins. Co.

Dist. Ct. did not err in granting plaintiff’s motion for summary judgment in ERISA action alleging that defendant-insurance company wrongfully determined that plaintiff was ineligible for long-term disability benefits because, according to defendant, plaintiff’s vision impairment failed to meet definition of disability in subject insurance policy. Under de novo review, plaintiff proved by preponderance of evidence that she was disabled under terms of policy. Moreover, Dist. Ct. could properly find that State of Illinois insurance regulation (i.e., 50 Ill. Admin. Code section 2001.3) applied so as to nullify provision in policy that reserved discretion to defendant to interpret terms of policy, even though defendant argued that section 2001.3 was preempted by ERISA, since section 2001.3 was specifically directed toward entities engaged in insurance and it substantially affected risk pooling arrangement between insurer and insured.