Leahy v. Raytheon Corporation

315 F.3d 11, 29 Employee Benefits Cas. (BNA) 2924, 2002 U.S. App. LEXIS 25903, 2002 WL 31819562
CourtCourt of Appeals for the First Circuit
DecidedDecember 17, 2002
Docket02-1215
StatusPublished
Cited by231 cases

This text of 315 F.3d 11 (Leahy v. Raytheon Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Leahy v. Raytheon Corporation, 315 F.3d 11, 29 Employee Benefits Cas. (BNA) 2924, 2002 U.S. App. LEXIS 25903, 2002 WL 31819562 (1st Cir. 2002).

Opinion

SELYA, Circuit Judge.

In this case, brought pursuant to the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. §§ 1001-1461 (2000), plaintiff-appellant Daniel J. Leahy alleges that defendant-appellee Metropolitan Life Insurance Company (MetLife), as the claims administrator for Raytheon Company’s long-term disability plan (the Plan), unreasonably denied his claim for benefits. The district court granted summary judgment in the defendants’ favor. 1 The plaintiff appeals. After addressing certain questions raised by the plaintiff anent the standard of review in ERISA benefit denial cases, we affirm.

I.

Background

The basic facts are uncontradicted. The Plan is an employee benefit plan funded by employee contributions and governed by ERISA. As the claims administrator, MetLife is responsible for making benefit determinations. For a participant to receive benefits, MetLife must determine that he is “fully disabled” as defined by the Plan. To meet that criterion, a claimant must show that by reason “of a sickness or an injury which is not covered by an applicable workers’ compensation statute ... [he or she] cannot perform the essential elements and substantially all of the duties of his or her job at Raytheon even with a reasonable accommodation.”

The plaintiff began working for Ray-theon in 1969. He eventually became a departmental administrator and a Plan participant. On October 18, 1996, Ray-theon furloughed him from that essentially sedentary position. The plaintiff received a severance benefit that included six months of salary continuation.

Over the years, the plaintiff has had more than his share of serious health problems; among other things, he has undergone three hip replacements and two knee replacements. In April of 1997, he applied for benefits under the Plan, claiming that he had become fully disabled on or about October 19, 1996 (the day after he was furloughed). The linchpin of his claim was an allegation that chronic hip pain prevented him from sitting for any length of time (and, therefore, prevented him from performing his job, even with a reasonable accommodation).

MetLife denied the claim on the ground that the plaintiff did not meet the Plan’s definition of “fully disabled.” In embellishing its decision, MetLife wrote that, taking into account available accommodations, the plaintiff had not established an inability to perform substantially all the duties of his job.

After exhausting his administrative remedies, the plaintiff filed suit in the United States District Court for the District of Massachusetts. He asserted that MetLife had violated ERISA when it unreasonably denied his claim. In due season, the parties cross-moved for summary judgment. The district court granted the defendants’ motion and denied the plaintiffs counter *15 part motion. Leahy v. Raytheon Co., No. 00-CV-12093, slip op. (D.Mass. Jan. 29, 2002) (unpublished). The court noted that the Plan vested broad discretionary authority in MetLife to determine eligibility for benefits and declared that while some medical evidence supported the plaintiffs claim of disability, other evidence supported MetLife’s denial of benefits. On that scumbled record, the court ruled that MetLife’s determination was neither arbitrary nor capricious. This timely appeal followed.

II.

Standard of Review

This denial-of-benefits claim arises under 29 U.S.C. § 1132(a)(1)(B). 2 The Supreme Court has provided the ground rules for determining the proper standard of review. In Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 109 S.Ct. 948, 103 L.Ed.2d 80 (1989), the Court stated that when a denial of benefits is challenged under ERISA § 1132(a)(1)(B), the standard of review depends largely upon whether “the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan.” Firestone, 489 U.S. at 115, 109 S.Ct. 948. If so, “Firestone and its progeny mandate a deferential ‘arbitrary and capricious’ standard of review.” Recupero v. New Engl. Tel. & Tel. Co., 118 F.3d 820, 827 (1st Cir.1997) (quoting Firestone, 489 U.S. at 115, 109 S.Ct. 948). The threshold question, then, is whether the provisions of the employee benefit plan under which remediation is sought reflect a clear grant of discretionary authority to determine eligibility for benefits. Terry v. Bayer Corp., 145 F.3d 28, 37 (1st Cir.1998); Rodriguez-Abreu v. Chase Manhattan Bank, 986 F.2d 580, 583 (1st Cir.1993). We turn, therefore, to the text of the Plan.

The Plan documents give MetLife “the exclusive right, in [its] sole discretion, to interpret the Plan and decide all matters arising thereunder....” The documents further provide that any decision by MetLife in the exercise of that authority “shall be conclusive and binding on all persons unless it can be shown that the ... determination was arbitrary and capricious.” This discretionary grant hardly could be clearer. Consequently, the arbitrary and capricious standard applies to judicial review of MetLife’s determination. 3

In an effort to blunt the force of this reasoning, the plaintiff makes two points. First, he suggests that a less deferential standard of review is appropriate in this case because the plan administrator operated under a conflict of interest. As a purely theoretical matter, this suggestion *16 rests on a sound foundation. It is well settled that when a plan administrator labors under a conflict of interest, courts may cede a diminished degree of deference — or no deference at all — to the administrator’s determinations. See, e.g., Doe v. Travelers Ins. Co., 167 F.3d 53, 57 (1st Cir.1999); Doyle v. Paul Revere Life Ins. Co., 144 F.3d 181, 184 (1st Cir.1998); Brown v. Blue Cross & Blue Shield of Ala., Inc., 898 F.2d 1556, 1562-64 (11th Cir.1990). But there is no meaningful conflict here, and so this case does not fit within that rubric. We explain briefly.

In the plaintiffs view, the ostensible conflict involves MetLife’s hiring of outside physicians to scrutinize the plaintiffs medical records. To affect the standard of review, however, a conflict of interest must be real.

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Bluebook (online)
315 F.3d 11, 29 Employee Benefits Cas. (BNA) 2924, 2002 U.S. App. LEXIS 25903, 2002 WL 31819562, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leahy-v-raytheon-corporation-ca1-2002.