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.