Unreported / Non-Citable
Background
Shifang Wong, a scientist at Adicet Bio working on cancer research and cell therapy products, sued Metropolitan Life Insurance Company (MetLife) under ERISA after it denied her long-term disability (LTD) benefits under her employer's plan. The court found that her job demanded four to eight hours of uninterrupted focus and zero tolerance for error, and that from 2021 she endured workplace bullying and harassment. In November 2023 her primary care physician, Dr. Gabriel Young, diagnosed major depressive disorder, panic attacks, and insomnia, noted memory and focus problems, and took her off work. From December 2023 to December 2024 Psychiatric Nurse Practitioner Nima Lal treated her two to three times a month and opined that returning to work would only worsen her condition.
The plan's disability definition is occupation-specific: a claimant must be unable, because of sickness or injury, to perform with reasonable continuity the substantial and material acts of her usual occupation. MetLife denied Wong's claim in February 2025 after psychologist Dr. Jess Ghannam reviewed her records, and affirmed in August 2025 after a second record reviewer, Dr. Elbert Richardson, found no validated evidence of impaired cognition. Separately, MetLife's psychiatric specialist Lorelie Nixon interviewed Wong by telephone and video on a short-term disability (STD) claim, found her limited in expressing thoughts, making decisions, and sustaining concentration, and MetLife awarded and extended those benefits. The parties cross-moved for judgment under Rule 52, and Wong moved to admit an extra-record workers' compensation report.
The Court’s Holding
Both sides agreed that de novo review applies, so the court gave MetLife's decision no deference and required Wong to prove disability by a preponderance of the evidence on the administrative record. It concluded she did and found her entitled to LTD benefits beginning November 8, 2023. The court found more persuasive the practitioners who interacted with her, namely Dr. Young, NP Lal, and Nixon, than MetLife's LTD reviewers, whose pure paper review raises questions about thoroughness, especially for subjective mental conditions. It emphasized the cognitive demands of her scientist role, so that even moderate impairment could prevent her usual work, and found that Drs. Ghannam and Richardson seemingly asked whether she could do any work at all, making their observations about suicidality and hospitalization of little relevance. Limited objective testing was not fatal, because subjective complaints cannot be discredited for lack of objective evidence, some testing showed severe anxiety, and MetLife never requested neuropsychological testing.
The STD award did not create a presumption of LTD entitlement, since the record did not show the STD plan's disability definition and the periods differed, but Nixon's findings in the record counted as additional evidence. The court declined to draw an adverse inference from the missing recording of Nixon's video interview. It rejected MetLife's three arguments: occasional notations that Wong felt okay or had intact cognition show only that she was not totally disabled; the record did not show her impairments were confined to Adicet; and the plan does not exclude conditions whose upstream cause was a hostile workplace. The motion in limine was denied without reaching its merits because the administrative record sufficed.
This is not yet a final judgment. The parties must confer on the benefits amount, file a joint statement of up to 10 pages by January 25, 2027 if they disagree, and attend a status conference on February 4, 2027. The court will enter final judgment once the amount is resolved.
Key Takeaways
- On de novo review, a court may find treating and interviewing clinicians more persuasive than reviewers who never met the claimant, particularly for subjective mental health conditions.
- Where a plan defines disability by usual occupation, reviewer opinions that do not address the job's specific cognitive demands carry limited weight.
- A lack of objective or neuropsychological testing does not defeat a claim when symptoms are documented and the insurer never requested such testing.
- A short-term disability award creates no presumption of LTD entitlement, but evidence generated in that process can still support the claimant.
- A hostile workplace as the upstream cause of a covered condition does not bar coverage under this plan's language.
Why It Matters
This is a district court order on cross-motions after a record-based bench trial and is not published precedent, but it applies settled Ninth Circuit authority, including Montour and Demer, to a mental health claim. It shows how an insurer's reliance on paper reviewers who do not address the claimant's actual occupation can fail under de novo review.
Relief is limited: the court found entitlement from November 8, 2023, but the benefit amount and final judgment remain open, and the extra-record evidence question was not decided.