Metropolitan Life Insurance Co. has been let out of a federal lawsuit alleging that an AstraZeneca employee's application for long-term disability was denied in violation of ERISA regulations. The pharmaceutical company, however, is still on the hook for some of the employee's other claims, including race and gender discrimination.
Deborah Brangman, who worked in AstraZeneca's marketing department from 1996 to 2011, filed the suit in early 2012 after she had been denied an extension of her short-term disability benefits by the company. She then sought long-term benefits from MetLife for her depression and anxiety. Her application was denied, as was her administrative appeal.
On June 24, a federal judge held that MetLife had acted within its discretion to deny Brangman's claim. The week before, U.S. District Judge Anita Brody of the Eastern District of Pennsylvania had let several of Brangman's claims against AstraZeneca survive the company's motions for summary judgment.
Brody wasn't persuaded by Brangman's argument that AstraZeneca had inappropriately influenced MetLife's decision to deny benefits, nor that the insurer was remiss in relying on the assessment of its independent consultant, who reviewed Brangman's medical records but wasn't involved with her treatment, to make its decision.
Regarding the first issue, about the drug company's influence on the insurer, Brangman had alleged that AstraZeneca's occupational health nurse, Betsy Rizzuto, had inappropriately told MetLife that her short-term disability application had been denied for a lack of medical support.
"The fact that Rizzuto relayed this information does not demonstrate that MetLife's own review of Brangman's claim was not independent," Brody said.
MetLife reviewed all of Brangman's medical records before denying her claim and then, again, on her appeal, Brody said.
"There is no evidence that relaying the reason for denying Brangman's short-term disability extension influenced MetLife's independent review of her LTD claim," Brody said.
Similarly, on the issue around MetLife's decision to employ an independent consultant to advise it on the appeal, Brody held that the insurer was within its rights.
Brangman had argued that the company had disregarded the input from her treating doctor in favor of the consultant's less informed view.
Brody noted that, "to be eligible for disability benefits, a claimant must not be able to perform his or her occupation for any employer in the geographic area where he or she resides," before deciding that "the basis of MetLife's denial of her appeal is that her records do not indicate her condition was severe enough to inhibit her from performing her marketing training position for another employer. In its discretion, MetLife chose to ascribe to Dr. [Marcus] Goldman's assessment. Claims administrators need not give special weight to the opinions of a claimant's physicians."
She cited the U.S. Supreme Court's 2003 decision in Black & Decker Disability Plan v. Nord.
A claimant's treating physicians aren't afforded special deference, Brody said, because there may well exist a conflict since the doctor may favor a finding for the patient.
"Choosing to rely on the non-treating medical consultant over the claimant's treating physicians does not render a denial of disability benefits arbitrary and capricious," she said. "MetLife considered the opinions of the medical professionals and ascribed to the view that Brangman's condition was not so severe so as to impede her from performing her job for any employer. The fact that her condition was intertwined and exacerbated by her interactions with AstraZeneca supports this fact."
The specific difficulties that Brangman had at work were detailed in Brody's opinion from the previous week, weighing AstraZeneca's motion for summary judgment. According to that opinion, Brangman's problems at work began to escalate in 2009 when she, a black woman, began reporting to a new supervisor, a white man.
She alleged various instances of race and gender discrimination in his attitude toward her.
Neil Hamburg of Hamburg & Golden in Philadelphia represented Brangman and declined to comment.
Veronica Saltz of Saltz Matkov in Wayne, Pa., represented MetLife and couldn't be reached for comment.
(Copies of the 19-page opinion in Brangman v. AstraZeneca, PICS No. 13-1405, are available from The Legal Intelligencer. Please call the Pennsylvania Instant Case Service at 800-276-PICS to order or for information.) •