Majeski v. Metropolitan Life Insurance

On March 4th Roy held a free webinar to share his analysis of the recent 7th Circuit Court of Appeals decision, Majeski vs. Metropolitan Life, and to have an open discussion with colleagues. Reviewing the case from the point-of-view of a “Thinking Evaluator,” Roy discussed five lessons and suggestions for practice for functional capacity evaluators.

Case Background

This appeal concerns MetLife’s decision to reject Majeski’s claim for short-term disability benefits [6 No. 09-1930]. The MetLife Short Term Disability Plan is governed by the Employee Retirement Income Security Act (ERISA).

As the plan administrator MetLife determined that Majeski had failed to submit enough evidence to support her claim. Majeski filed suit, but the district court granted summary judgment against her.

Although MetLife’s determination is entitled to deferential review, the court concludes that there are such significant gaps in the evidence supporting MetLife’s decision that further proceeding are necessary.

A list of the abbreviated lessons is below. At the end of this post you will find the audio and powerpoint slides to the presentation, where there will be more detail.

• Lesson One
  Take the time to read court cases and continually study to strengthen your skills!
• Lesson Two
  Understand the audience of your Functional Capacity Evaluation. [2 and 13 No. 09-1930]
• Lesson Three
  Have the proper references at hand. [2 and 13 No. 09-1930]
• Lesson Four
  Read the summary of the Court’s opinion. [1 and 2 No. 09-1930]
• Lesson Five
  Find points interesting to a Functional Capacity Evaluator, such as Federal Rules of Evidence, Arbitrary-and-Capricious decisions [11 No. 09-1930], and Procedural reasonabless [7, 10, 11 No. 09-1930;12, 10 No. 08-1362; 11 No. 1:06-cv-01136; 1 No. 02-469].