Demer v. IBM Corporation LTD Plan

In Demer v. IBM Corporation LTD Plan, ____________ (9th Cir. 2016), the Ninth Circuit reversed the district court's entry of judgment in favor of defendants IBM Corporation LTD Plan (the "Plan") and Metropolitan Life Insurance Company ("MetLife"), the claims administrator and insurer for the Plan, with instructions to re-evaluate the merits of plaintiff Demer's long term disability ("LTD") claim.

Demer was an employee of IBM Corporation, and a participant in the Plan. The Plan gave MetLife the discretionary authority to interpret the Plan and determine eligibility for benefits. As such, the Ninth Circuit determined it would apply an abuse of discretion standard of review, not de novo.