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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Wojciechowski v. Metropolitan Life Insurance

Plaintiff Paul J. Wojciechowski sued Metropolitan Life Insurance Company (Met Life) and IBM Corporation, his former employer, under the Employee Retirement Income Security Act of 1974 (ERISA), alleging wrongful denial of Long Term Disability (LTD) and Separation Pay benefits. Wojciechowski, an IBM employee since 1980, suffered back and spinal injuries from a 1993 car accident, leading to medical leaves and reports from his physician, Dr. Pani, indicating permanent disability. Met Life, the LTD plan administrator, denied his claim in 1997, a decision upheld on appeal. IBM also denied him severance pay, deeming his separation a voluntary resignation after his S&A leave expired and he failed to return to work. The court applied an arbitrary and capricious standard of review to Met Life's decision, finding it supported by substantial evidence and unaffected by a conflict of interest. Summary judgment was granted to IBM on the disability claims as it was not a fiduciary, and to both IBM and Met Life on all claims.

ERISALong Term Disability BenefitsSeverance PaySummary JudgmentArbitrary and Capricious StandardDe Novo ReviewFiduciary DutyPlan AdministratorConflict of InterestEmployee Benefits
References
26
Case No. MISSING
Regular Panel Decision
Jan 14, 1991

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.

ERISAAccidental Death BenefitsSummary JudgmentDe Novo ReviewDiscretionary AuthorityPre-existing ConditionCoronary ArteriosclerosisCausationWorkers' CompensationInsurance Contract
References
63
Case No. MISSING
Regular Panel Decision

Yuhas v. Provident Life & Casualty Insurance

Deborah Yuhas sued Provident Life and Casualty Insurance Company under ERISA for long-term disability benefits, claiming physical disability. Yuhas, a graphic designer, initially received benefits for a mental condition, which ceased after 24 months due to policy limitations. She subsequently appealed, claiming physical disabilities from a car accident, leading to a retroactive award of benefits for a specific period (October 1991 through May 1993) but no further benefits. Provident repeatedly denied her claim for benefits beyond May 1993, citing lack of objective physical disability and the expiration of appeal periods. Yuhas filed suit in September 2000, but the court granted Provident's motion for summary judgment, ruling that her claim was barred by the three-year statute of limitations, which had accrued by December 13, 1993, at the latest.

ERISALong Term Disability BenefitsSummary JudgmentStatute of LimitationsAccrual of Cause of ActionDisability Insurance PolicyMental DisorderPhysical InjuryAppeals ProcessRepudiation of Claim
References
13
Case No. MISSING
Regular Panel Decision

Metropolitan Life Insurance v. Durkin

The plaintiff, Metropolitan Life Insurance Company, initiated an action seeking a declaration that sections 213 and 213-a of the New York State Insurance Law prohibited the retroactive payment of a wage increase. This increase of $2.85 per week was awarded by the National War Labor Board to its insurance agents, dating back to the start of arbitration proceedings. The plaintiff argued these statutes, designed to prevent excessive post-facto compensation, made such retroactive payments unlawful. However, the trial court and Appellate Division, whose decision was affirmed, concluded that the statutes were not intended to interfere with the common practice of collective bargaining and arbitration, which frequently involves retroactive wage adjustments. The court emphasized that the legislative intent behind the insurance laws was to curb abuses like bonuses and gratuities, not to hinder ordinary and orderly wage-fixing mechanisms, thereby affirming the legality of the retroactive wage increase.

Insurance RegulationRetroactive CompensationCollective Bargaining DisputesWage Arbitration AwardNew York Insurance LawLabor Relations BoardStatutory InterpretationAppellate Court RulingEmployee Benefits LitigationContractual Agreements
References
5
Case No. MISSING
Regular Panel Decision

Veryzer v. American International Life Assurance Co.

Robert Veryzer, Ph.D. ("Plaintiff") sued American International Life Assurance Company of New York ("AI Life") under ERISA, challenging the insurer's denial of his long-term disability benefits. AI Life had limited benefits to 24 months, classifying Veryzer's disability as "Mental Illness" despite extensive medical evidence from his treating physicians and neuropsychologists attributing it to mercury poisoning from Hepatitis A and B vaccinations. The court found AI Life's decision arbitrary and capricious, unsupported by substantial evidence, citing the insurer's reliance on non-examining experts who ignored medical literature and procedural irregularities in the claims process. Highlighting AI Life's conflict of interest as both administrator and payor, the court denied AI Life's motion for summary judgment, granted Veryzer's cross-motion, reversed the denial of benefits, and ordered AI Life to provide the requested coverage.

ERISA claimsLong-term disabilitySummary judgment motionsArbitrary and capricious reviewMercury toxicityVaccination injuryCognitive impairment benefitsMedical expert testimonyInsurance bad faithClaims processing irregularities
References
26
Case No. MISSING
Regular Panel Decision

Watso v. Metropolitan Life Insurance

Plaintiff Thomas J. Watso was injured after falling from a building under construction while performing welding work. He, along with his wife, initiated an action against Metropolitan Life Insurance Company and Gilbane Building Company, alleging a violation of Labor Law § 240 (1). The Supreme Court initially granted the plaintiffs' motion for partial summary judgment on the issue of liability. However, the defendants appealed, presenting evidence that Watso might have deliberately chosen not to use a provided static line, thereby raising the defense of a recalcitrant worker. The appellate court reversed the Supreme Court's decision, concluding that there was a legitimate triable issue of fact concerning the adequacy of the safety device provided and whether Watso was indeed a recalcitrant worker, ultimately denying the motion for partial summary judgment.

Workers' CompensationConstruction AccidentFall from HeightSummary JudgmentLabor LawRecalcitrant WorkerSafety DevicePersonal InjuryAppellate ReviewTriable Issue of Fact
References
4
Case No. MISSING
Regular Panel Decision

Saxe v. Metropolitan Life Insurance

Claimant Saxe sued Metropolitan Life Insurance Co. for reimbursement of a special teacher's cost for his daughter, Elana, who suffers from cortical visual impairment. This lawsuit followed a prior favorable decision for Saxe, after which the insurer amended its contract to narrowly define "Provider," effectively excluding the specialized visual therapy services. Despite Saxe's request for an alternative "Provider" from Metropolitan Life, none could be supplied under the new contract definition to provide the medically necessary services. The court ruled in favor of the claimant, stating that the insurer could not indirectly exclude medically necessary coverage through an unfulfillable "Provider" definition, as policies are strictly construed against the drafter. Judgment was rendered to the claimant for $1,823 plus costs, disbursements, and interest, finding the defendant's exclusion attempt ineffective.

Insurance coverageMedical expensesContract disputeProvider qualificationsVisual impairmentSpecial education servicesHealth policyClaim reimbursementAmbiguous contract termsInsurer liability
References
5
Case No. MISSING
Regular Panel Decision

Sheehan v. Metropolitan Life Insurance

Plaintiff James C. Sheehan moved for attorney's fees after successfully suing Metropolitan Life Insurance Company for wrongful termination of long-term disability benefits. The court had previously ruled that MetLife wrongfully terminated benefits and awarded Sheehan $218,235.24, which was affirmed on appeal. MetLife argued against the fee award or sought a reduction due to Sheehan's partial success. The court, presided over by Senior District Judge Haight, found Sheehan was a "prevailing party" and calculated a lodestar fee of $123,387.50 after adjusting hourly rates for some attorneys and disallowing time for pre-suit administrative proceedings. Due to Sheehan's partial success, the court applied a 30% downward adjustment, ultimately awarding $86,371.25 in attorney's fees to Sheehan.

ERISAAttorney's FeesDisability BenefitsWrongful TerminationLodestar MethodPartial SuccessPrevailing PartySecond CircuitDistrict CourtInsurance Policy
References
17
Case No. MISSING
Regular Panel Decision

Centennial Life Insurance v. Nappi

Centennial Life Insurance Company sued Anthony Nappi for fraudulently misrepresenting his birth date to collect disability benefits he was not entitled to. Nappi initially claimed a 1928 birth year, entitling him to benefits until age 65, but later asserted a 1938 birth year for lifetime benefits. Centennial's investigation revealed substantial evidence supporting the 1928 birth year, while Nappi's contradictory evidence was found to be dubious or refuted. The court drew an adverse inference from Nappi's invocation of the Fifth Amendment and denied his request to reopen discovery. The court found no ambiguity in the insurance policy's terms regarding benefit termination. Consequently, the court granted summary judgment for Centennial, concluding Nappi committed fraud and was liable for $85,000 in overpaid benefits, plus costs and interest, totaling $95,070.02, with Centennial's obligation terminating on March 22, 1993.

fraudmisrepresentationdisability insurancesummary judgmentbirth date disputebreach of contractFifth Amendment privilegeoverpayment of benefitspolicy interpretationmedical records
References
11
Case No. MISSING
Regular Panel Decision

Baumann v. Metropolitan Life Insurance

Plaintiff's decedent, Frederick Baumann, an experienced electrician, was electrocuted on the job in 1999 while working on office space leased by Credit Suisse and owned by Met Life. Plaintiff commenced a wrongful death action against Met Life, Credit Suisse, and Penguin Air Conditioning Corp., alleging liability under Labor Law § 241 (6) for a violation of 12 NYCRR 23-1.13 (b) (4). The trial court granted summary judgment to Credit Suisse and Met Life, concluding that the decedent was the sole proximate cause of his death. The appellate court reversed this decision, finding that the trial court improperly made findings of fact and that there were questions of fact concerning the defendants' liability and the extent of the decedent's responsibility.

Wrongful DeathElectrocutionSummary JudgmentLabor LawProximate CauseSuperseding ActAppellate ReviewConstruction AccidentElectricianOccupational Hazard
References
1
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