Judge Upholds HIV-Positive Worker's LTD Denial

US District Judge Shira Scheindlin of the US District Court for the Southern District of New York ruled that Metropolitan Life did not act unreasonably in turning down a request by plaintiff Mark Winkler for disability benefits due to his HIV and accompanying depression.

Winkler, laid off as a vice president and senior creative director from marketing agency Jack Morton Co. in October 2001 as part of a series of personnel reductions, applied for the coverage in January 2002. In response, Metropolitan Life denied his request, stating that Winkler was able to work on a daily basis for years despite his HIV, that he had worked as a freelancer for Jack Morton for five days after his employment was terminated and that representatives of Jack Morton had stated that Winkler was laid off solely due to the company’s reduction in force. Winkler appealed the decision administratively and then filed suit.

In her ruling, Scheindlin said Metropolitan Life gave Winkler a full and fair review, in that Metropolitan Life informed Winkler exactly why it was denying his claim and which information it considered persuasive in making that determination. The court concluded that there was substantial evidence to support Metropolitan Life’s benefits denial.

In addition, the court said it was not unreasonable for Metropolitan Life to consider Winkler’s freelance work as evidence of his ineligibility for benefits.

“None of the opinions on which MetLife relied in making its decision were unreasonable or irrational; nor can they be construed on their face, as products of bias or self-interest,” Scheindlin wrote. “Accordingly, this court cannot conclude that MetLife’s denial of benefits fell outside the realm of its discretion so as to constitute an arbitrary and capricious decision.”

The case is Winkler v. Metropolitan Life Insurance Co., S.D.N.Y., No. 03 Civ. 9656 (SAS), 4/18/05.