Arthurs v. Metropolitan Life Insurance
Catherine Arthurs sued Metropolitan Life Insurance Company for accidental death benefits following her husband Raymond Arthurs' death, which she attributed to strenuous work in a hot vault. Metropolitan denied benefits, citing Raymond's pre-existing coronary arteriosclerosis. The court determined that Metropolitan's benefit denial must undergo a de novo review under ERISA federal common law, rejecting the insurer's claim of discretionary authority given the plan's wording. Finding genuine disputes of material fact regarding the causal relationship between Mr. Arthurs' heart condition and his death, the District Court denied Metropolitan's motion for summary judgment.