Ms. Holmstrom suffered from a painful nerve condition in her right arm which did not resolve even after three surgeries. She was left with an incurable diagnosis of complex regional pain syndrome (CRPS). MetLife paid benefits until the definition of disability changed from an inability to perform the material duties of one’s own occupation to that of any occupation. MetLife cited the lack of any objective evidence to support Ms. Holmstrom’s diagnosis of CRPS.
MetLife’s Requirement of Objective Medical Evidence To Support A Disability Claim Was Arbitrary Under ERISA
The court recognized that painful conditions like CRPS and fibromyalgia posed difficult problems for disability insurance companys who seek to make decisions based on the most objective evidence available. However, the court rejected as arbitrary MetLife’s requirement that a claimant prove her condition with objective data where no definitive objective test exists for the condition.
The court pointed out that there was no evidence in the record to support MetLife’s conclusion that Ms. Holmstrom’s complaints of pain were not credible. She had undergone unsuccessful surgeries for pain relief, was on heavy pain medication, and her treating doctors were supportive that her pain was consistent with their findings. Her complaints of pain were believable.
Objective Measurements of Functional Limitations Should Be Submitted In Support Of A Long Term Disability Claim.
Even in cases involving conditions where subjective symptoms of pain are not manifest in objective clinical data, the court did approve the insurer requiring a certain degree of objectivity in terms of the measurement of physical limitations. It pointed out that this can readily be done through a proper Functional Capacity Evaluation (FCE). Thus, the court makes a distinction between trying to measure the amount of fatigue or pain an individual experiences with how the individual’s fatigue or pain limits his functional capacities, which can be objectively measured through an FCE.
Ms. Holmstrom had submitted an FCE report indicating she was functionally disabled as a result of her pain. This report was ignored by MetLife. The court found that failing to consider Ms. Holmstrom’s credible FCE evidence was also arbitrary and an abuse of discretion.
To view the full case opinion, please see Holmstrom v. Metropolitan Life Insurance Company, 615 F.3d 758 (7th Cir. 2010).