Diagnosis is Not Disability: Lessons from the Eleventh Circuit’s Ruling in Hovan v. MetLife
For high-functioning professionals, the onset of a debilitating mental health condition is a profound crisis. It threatens not only one’s well-being but also one’s career and financial stability. When that safety net—long-term disability (LTD) insurance—is pulled away, the consequences are often catastrophic. A recent decision from the United States Court of Appeals for the Eleventh Circuit, Stacy Hovan v. Metropolitan Life Insurance Company, serves as a stark reminder of the rigorous hurdles claimants face under ERISA. This case illustrates a critical, often misunderstood reality of disability insurance law: a diagnosis, no matter how severe, does not automatically equal a disability.
As an experienced ERISA lawyer, I frequently encounter clients who are baffled when their benefits are terminated despite ongoing medical treatment. The Hovan decision provides a textbook example of how insurance giants like MetLife leverage clinical documentation gaps to deny claims and why having seasoned legal counsel is essential to protecting your rights under Section 502(a).
The Case: Hovan v. Metropolitan Life Insurance Company
Stacy Hovan was a commercial litigator at a prominent law firm, a role that demanded high-level cognitive functioning, critical thinking, and the ability to manage intense stress. Her career was interrupted by a resurgence of bipolar disorder, a condition she had managed for years but which eventually precipitated a mental health crisis requiring hospitalization.
Initially, MetLife approved her claim for long-term disability benefits. Her treating psychiatrist had documented “impaired judgment,” “poor decision making,” and an inability to handle stress—limitations that clearly precluded her from working as a litigator. However, the landscape of her claim changed after she was discharged from a partial hospitalization program in late 2020. Her discharge summary noted a “good prognosis,” stating she was “safe to discharge” and that her mood was stable.
Based largely on this discharge summary and subsequent therapy notes, MetLife terminated her benefits. Hovan appealed administratively and then filed a lawsuit under ERISA Section 502(a). On November 20, 2025, the Eleventh Circuit Court of Appeals affirmed the termination, ruling that Hovan had failed to meet her burden of proving she remained disabled.
The “Therapy Note” Trap: Clinical Progress vs. Occupational Disability
The crux of the Hovan decision—and a common pitfall in mental health disability claims—is the disconnect between therapeutic goals and legal standards. In therapy, a provider’s notes often focus on relative progress. A therapist might note that a patient is “interactive,” “alert,” or “stable” because the patient is no longer in immediate crisis or requiring hospitalization. In Hovan, the court seized on these descriptors. It noted that while Hovan continued to experience mood fluctuations and even “fleeting” suicidal ideation, her therapist consistently recorded her “functional status” as “intact”. MetLife argued, and the court agreed, that these notes did not prove she was unable to perform the material duties of a commercial litigator.
The Court’s rationale highlights a dangerous nuance in disability insurance claims. A patient may be “stable” enough to live safely in the community but wholly unable to draft complex motions, argue in court, or manage the intellectual rigors of legal practice. Without a medical opinion connecting the symptoms (e.g., anxiety, mania) to specific occupational limitations (e.g., inability to concentrate for more than 15 minutes, inability to make reasoned judgments under time pressure), a claim is vulnerable.
The Burden of Proof and the So-Called “Administrative Record“
Under ERISA, the burden of proof lies on the claimant to demonstrate entitlement to benefits. This burden must be met during the administrative appeal process—before a lawsuit is ever filed. One of the most damaging aspects of the Hovan case was the plaintiff’s failure to supplement the record when given the chance.
During the internal appeal, MetLife provided Hovan with a report from an independent file reviewer who concluded she was no longer disabled. MetLife explicitly invited Hovan to submit additional clinical evidence to refute this finding. Hovan’s counsel at the time declined, instructing MetLife to proceed with the decision based on the existing record.
This was a critical strategic error. In ERISA litigation, the court’s review is often limited to the so-called “administrative record”—the pile of documents that existed when the insurance company made its final decision. This is especially true when the claim is reviewed under the deferential “abuse of discretion” or “arbitrary and capricious” standard of review. If the evidence of disability isn’t in that file, it typically cannot be used in court. By declining to submit new or clarifying evidence linking her condition to her specific job duties, Hovan left the court with only the “intact” therapy notes and the adverse file review. The court noted that Hovan “made no effort to supplement the record… despite knowing MetLife considered [the] therapy notes insufficient”.
Why “File Reviews” Are Permissible
Many claimants are shocked when an insurance company denies their claim based on the opinion of a doctor who has never met them—a “paper review” or file review. Hovan argued that it was improper for MetLife to rely on a file reviewer who hadn’t examined her. The Eleventh Circuit rejected this argument, reaffirming that plan administrators are permitted to rely on independent medical file reviews, provided the review is not arbitrary.
The court found that the file reviewer’s report was detailed and addressed Hovan’s symptoms, noting a lack of evidence regarding “impairment in insight and judgment”. Because Hovan did not provide contrary evidence from her own treaters that specifically addressed these vocational capacities, the file reviewer’s opinion apparently stood unrefuted.
How an Experienced ERISA Lawyer Makes the Difference
The outcome in Hovan underscores why specialized legal representation is non-negotiable in LTD claims. An experienced LTD lawyer who understands that medical records generated for treatment purposes are rarely sufficient for legal purposes. Treating physicians are focused on clinical care, not disability definitions. They may write “doing better” to encourage a patient, not realizing that an insurance adjuster will read “doing better” as “ready to return to work.”
At The Garner Firm, we anticipate these tactics. We do not simply forward medical records to the insurance company; we actively curate the administrative record to ensure it contains the precise evidence needed to withstand judicial scrutiny. Having a firm that will fight for you is critically important.
The Garner Firm Advantage
The Garner Firm brings a unique depth of perspective to ERISA litigation. With experience handling ERISA claims since 2007, I have not only represented plaintiffs but have also previously represented employers, plans, and fiduciaries. I have even served as a plan administrator for a large union pension plan. This background provides valuable perspective.
As a Senior Editors of the treatise Employee Benefits Law, our attorneys are at the forefront of the complex statutory and regulatory landscape that governs these claims. This expertise is critical because ERISA is a minefield of technicalities—from strict appeal deadlines to the deferential “arbitrary and capricious” standard of review that makes overturning a denial so difficult.
Don’t Fight MetLife Alone
The Hovan decision is a sobering reminder that in the world of ERISA and disability insurance, the truth of your suffering is often secondary to the quality of your evidence. MetLife and other insurers are sophisticated entities with vast resources and legal teams dedicated to minimizing their liability. To prevail, you need an advocate who matches their sophistication and aggression.
If you are facing a denial of long-term disability benefits, or if you are considering filing a claim for a mental health condition, do not rely on your medical diagnosis alone to protect you. You need a strategy that bridges the gap between medicine and law.
Contact The Garner Firm today. Let us put our decades of experience and deep understanding of ERISA regulations to work for you. We know how to build a record that stands up in court, and we are dedicated to fighting for the benefits you have earned.
Disclaimer: This blog post is for informational purposes only and does not constitute legal advice. The outcome of any legal matter depends on the specific facts and applicable law. Contact a qualified attorney for advice regarding your specific situation.