Unreported / Non-Citable
Background
Jason Grice, a Senior Solutions Consultant at Google, underwent reconstructive surgery for a foot and ankle deformity caused by Charcot-Marie-Tooth syndrome. He received short-term disability benefits during his recovery, but medical records showed improving mobility and an ability to walk and climb stairs. Although his surgeon initially cleared him to return to full-time work without restrictions in July 2022, the surgeon later extended that date to September.
Grice sought long-term disability benefits under Google’s employer-provided plan, which Metropolitan Life Insurance Company administered. MetLife denied the claim after medical and vocational reviewers concluded that Grice could perform his sedentary occupation after March 2022, subject to certain restrictions. MetLife upheld the denial on administrative appeal, and the district court granted it summary judgment on Grice’s ERISA claim.
The Court’s Holding
The Fifth Circuit affirmed. It declined to decide whether the plan validly delegated discretionary authority to MetLife or whether Texas or California prohibitions against such clauses applied. The court expressed doubt that an ERISA plan could use a choice-of-law provision to leave an insured unprotected by either state’s insurance law, but held that the dispute over the standard of review was immaterial because MetLife’s decision survived de novo review.
Under the plan, Grice had to show that he could not perform the substantial and material duties of his usual occupation with reasonable continuity after the 180-day elimination period. The record did not establish that level of disability. Grice’s Google position was sedentary, involving mostly sitting and only brief periods of walking or standing, and the medical evidence indicated that he could return to that role after July 2022 with accommodations for his recovery.
Key Takeaways
- The court assumed de novo review because the denial of benefits was sustainable even under that nondeferential standard.
- The panel did not resolve whether the plan’s choice-of-law provision could avoid both Texas and California restrictions on discretionary clauses.
- Medical limitations do not establish total disability when the claimant can still perform the material duties of a sedentary occupation with appropriate restrictions.
Why It Matters
The decision shows that courts may bypass difficult ERISA choice-of-law and delegation questions when the benefits determination withstands de novo review. It also underscores that an occupational-disability claim turns on the plan’s precise language and the relationship between documented functional limitations and the claimant’s actual job duties.