Holmstrom v. Metropolitan Life Ins. Co.

Dist. Ct. erred in granting defendant-plan administrator's motion for summary judgment in ERISA action alleging that defendant wrongfully terminated plaintiff's long-term disability benefits even though plaintiff asserted that she could no longer work in any occupation as result of painful nerve condition in her right arm. Plaintiff need not prove her condition only through use of objective data where, as here, no definite objective test exists for plaintiff's condition, and record showed that instant denial was arbitrary where: (1) certain functional capacity evaluations (FCE) indicated that plaintiff had total disability; (2) defendant failed to explain why it found most recent FCE unreliable; (3) defendant failed to consider fact that plaintiff satisfied requirements for receiving SSI benefits; (4) record failed to support defendant's claim that plaintiff's surgeries had resolved her condition; (5) defendant relied on opinions of physicians who had never examined plaintiff; and (6) defendant repeatedly imposed new testing requirements once plaintiff had satisfied prior requirements.