Symptoms Are Not Enough: Functional Impairment and the ERISA Claimant’s Burden in Mental‑Health Disability Claims
Commentary on Stacy Hovan v. Metropolitan Life Insurance Company (11th Cir. Nov. 20, 2025)

I. Introduction

This Eleventh Circuit opinion in Stacy Hovan v. Metropolitan Life Insurance Company addresses a recurring and difficult question in ERISA disability litigation: what kind of evidence must a claimant provide to prove continuing disability due to a mental health condition, especially once an insurer has previously approved benefits?

The plaintiff, Stacy Hovan, was a high‑level commercial litigator whose work required sophisticated cognitive and interpersonal functioning. She suffered from bipolar disorder, ceased working during a significant mental health crisis, and initially obtained long‑term disability benefits under her firm’s ERISA‑governed plan insured and administered by Metropolitan Life Insurance Company (“MetLife”). After a later period of partial hospitalization, MetLife terminated benefits as of the discharge date, contending that the available clinical evidence no longer showed that Hovan was unable to perform the material duties of her “Own Occupation.”

The district court upheld MetLife’s termination on de novo review, and the Eleventh Circuit has now affirmed. The appellate court’s opinion is marked “Not for Publication,” so it is not binding precedent under Eleventh Circuit rules; nonetheless, it provides a detailed and instructive application of the Blankenship six‑step framework for ERISA benefit denials and elaborates on several important principles:

  • The ERISA claimant’s burden to prove continuing disability under plan terms.
  • The distinction between psychiatric symptoms and occupational functional impairment.
  • The legal significance of passive suicidal ideation in disability analysis.
  • The permissibility of relying on file‑reviewing physicians rather than in‑person examinations.
  • The consequences of a claimant’s decision not to supplement the administrative record when invited.

In substance, the case stands for the proposition captured in the title: under ERISA, the mere presence of ongoing mental‑health symptoms—even serious ones—does not suffice to establish disability absent evidence that those symptoms translate into concrete, work‑precluding functional limitations.

II. Summary of the Opinion

A. Parties and Plan Context

Hovan worked as a commercial litigator at Troutman Sanders LLP, specializing in complex litigation. The firm provided long‑term disability coverage through a MetLife group policy. The plan:

  • Provided up to 24 months of long‑term disability benefits for disabilities caused by mental or nervous disorders.
  • Defined “Own Occupation” for attorneys as “the specialty in the practice of law in which You were engaged just prior to the date Disability started,” not limited to the specific employer or position.
  • Gave MetLife express discretionary authority to interpret the plan and determine eligibility, with decisions to be upheld unless “arbitrary and capricious.”
  • Stated that disability benefits would end, among other things, on “the date You fail to provide required Proof of continuing Disability.”

B. Factual and Procedural Background

Hovan, diagnosed with bipolar disorder in 2005, stabilized and later attended law school without recurrent episodes for years. In 2019 she experienced a new mental health crisis, stopped working, and began treatment with psychiatrist Dr. Michael Lara. His 2019 records—emphasizing impaired judgment, poor decision‑making, mood instability, and limited stress tolerance—supported MetLife’s initial approval of long‑term disability benefits from June 1, 2019.

In late 2020, Hovan spent several weeks in a partial hospitalization program at PeakView Behavioral Health. Her discharge psychiatrist, Dr. Sohail Punjwani, noted a “good prognosis” and documented a stable mood, no anxiety or depression, absence of suicidality or psychosis, and no imminent risk.

After discharge, Hovan engaged in therapy with Sherrie Stevens from November 2020 through early March 2021. Stevens’s notes reported fluctuating mood, occasional depression, mania, anxiety, and some fleeting, passive suicidal thoughts without intent or plan. Hovan had also at times discontinued her medications. Importantly, however, Stevens repeatedly documented that:

  • Hovan’s “functional status” was “intact,”
  • Her affect was “appropriate,”
  • Her cognition was “oriented/alert,” and
  • Her interpersonal functioning was “interactive.”

Stevens did not offer any opinion on occupational limitations or on Hovan’s ability to work as a commercial litigator.

In January 2021, MetLife re‑evaluated the claim, attempted unsuccessfully to reach Stevens, reviewed the therapy notes, and decided to terminate benefits effective October 16, 2020 (the PeakView discharge date), based on an asserted lack of proof of continuing disability.

On administrative appeal, MetLife obtained a file review by psychiatrist Dr. Sarah Ghebrendrias. She concluded there was “no evidence of findings to suggest limitations” after discharge: aside from depressed/anxious mood and passive suicidal ideation without plan or intent, the record showed no psychosis, no psychomotor agitation, no suicidal or homicidal intent, no self‑destructive behavior, no involuntary hospitalization, no lack of motivation, and no impairment of insight or judgment. She thus found no supported work‑related restrictions or limitations.

MetLife shared this report with Hovan, invited additional clinical evidence, and—at the direction of Hovan’s counsel, who chose not to submit anything further—proceeded to uphold its termination decision.

Hovan then filed suit under ERISA § 502(a)(1)(B), 29 U.S.C. § 1132(a)(1)(B), challenging MetLife’s termination as both “wrong” and “unreasonable.” Both parties moved for summary judgment. The district court, conducting a de novo review of the administrative record, held that MetLife’s termination decision was not wrong and granted summary judgment for MetLife.

C. Holding of the Eleventh Circuit

The Eleventh Circuit:

  • Reviewed de novo the district court’s summary judgment ruling.
  • Applied the six‑step Blankenship framework for ERISA benefit denial review.
  • Concluded at Step 1 that MetLife’s termination decision was not de novo wrong because the evidence did not demonstrate that Hovan remained unable to perform the material duties of her “Own Occupation” as a commercial litigator after October 16, 2020.
  • Held that, since the decision was not wrong at Step 1, the court’s analysis ended; it did not proceed to consider discretionary deference, arbitrary‑and‑capricious review, or conflict‑of‑interest issues.
  • Rejected Hovan’s challenges to MetLife’s evidentiary demands and its reliance on a file‑reviewing psychiatrist.
  • Affirmed the district court’s judgment in MetLife’s favor.

Central to the holding is the court’s insistence that the plaintiff bears the burden of proving continuing disability and that the therapy notes—despite documenting ongoing symptoms and passive suicidal ideation—did not supply evidence of work‑precluding functional limitations or uncontrolled impairment.

III. The Legal Framework

A. ERISA Cause of Action

ERISA § 502(a)(1)(B), 29 U.S.C. § 1132(a)(1)(B), allows a plan participant to sue:

“to recover benefits due to him under the terms of his plan, to enforce his rights under the terms of the plan, or to clarify his rights to future benefits under the terms of the plan.”

Such cases are typically resolved on the administrative record developed during the insurer’s claim and appeal process, often via cross‑motions for summary judgment, as here.

B. Standard of Judicial Review: Firestone, Glenn, and Blankenship

ERISA is silent on the standard of review for adverse benefit determinations. In Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (1989), the Supreme Court established the baseline rule:

  • De novo review applies unless the plan grants the administrator discretionary authority to determine eligibility or construe plan terms.
  • If the plan does grant such discretion, courts use a deferential abuse‑of‑discretion/arbitrary‑and‑capricious standard.
  • If the administrator operates under a conflict of interest (e.g., both paying and deciding claims), that conflict is a factor weighing in the arbitrary‑and‑capricious analysis, as elaborated in Metropolitan Life Insurance Co. v. Glenn, 554 U.S. 105 (2008).

The Eleventh Circuit synthesizes this into a structured six‑step approach, articulated in Blankenship v. Metropolitan Life Insurance Co., 644 F.3d 1350 (11th Cir. 2011):

  1. Apply de novo review to ask whether the administrator’s decision was “wrong.” If not, affirm.
  2. If wrong, ask whether the administrator had discretion. If not, reverse.
  3. If wrong and discretion exists, ask whether reasonable grounds support the decision under arbitrary‑and‑capricious review.
  4. If no reasonable grounds exist, reverse. If reasonable grounds exist, consider conflict of interest.
  5. If no conflict, affirm.
  6. If conflict, treat it as one factor in deciding whether the decision was arbitrary and capricious.

Because the MetLife plan expressly granted discretionary authority, this framework governed. However, the court decided the case at Step 1: it held the termination decision was not wrong even under de novo review.

C. Claimant’s Burden of Proof

The opinion reiterates a foundational ERISA principle: the plaintiff bears the burden of proving entitlement to benefits under the contract. Citing Glazer v. Reliance Standard Life Ins. Co., 524 F.3d 1241 (11th Cir. 2008), and Horton v. Reliance Standard Life Ins. Co., 141 F.3d 1038 (11th Cir. 1998), the court emphasizes that this burden includes:

  • Proving initial disability under the plan’s definition, and
  • Proving continuing disability when benefits are conditioned on the ongoing submission of adequate proof.

The Plan here explicitly provided that benefits stop on “the date You fail to provide required Proof of continuing Disability.” Thus, termination was justified if Hovan ceased to carry that evidentiary burden, even though she had previously been found disabled.

D. Plan Definitions and Structure

Two features of the plan’s design are particularly important:

  1. “Own Occupation” for Attorneys:
    For attorneys, “Own Occupation” means “the specialty in the practice of law in which You were engaged just prior to the date Disability started.” Thus, the question was whether Hovan could perform the material duties of a commercial litigator, not simply any job.
  2. Time‑limited coverage for mental/nervous disorders:
    The Plan limited coverage for “mental or nervous disorders” to 24 months under the “Own Occupation” standard. Although the opinion does not reach the 24‑month limit question (Hovan’s benefits were terminated earlier), this framework underlies the analysis: as of October 16, 2020, MetLife was still assessing disability relative to her own specialty, not “any occupation.”

IV. Precedents Cited and Their Influence

A. Firestone and Glenn (via Alexandra H.)

The court relies on its prior decision in Alexandra H. v. Oxford Health Ins. Inc. Freedom Access Plan, 833 F.3d 1299 (11th Cir. 2016), to restate the Firestone/Glenn framework. That case distilled the Supreme Court’s holdings and clarified how the Eleventh Circuit decides whether to apply de novo or deferential review in ERISA benefits cases. Here, that framework is invoked to justify applying the Blankenship six‑step test.

B. Blankenship v. Metropolitan Life Insurance Co.

Blankenship is the backbone of the court’s analytical structure. It supplies:

  • The six‑step test for deciding which standard of review applies and how conflicts of interest matter.
  • Authority that plan administrators may legitimately rely on “file reviews” by independent doctors instead of live physical examinations. The court quotes its prior holding that use of file reviews, “particularly in the absence of other troubling evidence,” is not itself evidence of arbitrary or capricious decision‑making.

In this case, Blankenship plays a dual role:

  1. Procedurally, it guides the court to stop at Step 1 once it finds MetLife’s decision was not de novo wrong.
  2. Substantively, it legitimizes MetLife’s reliance on Dr. Ghebrendrias’s file review rather than insisting on an in‑person psychiatric evaluation.

C. Glazer and Horton: Burden of Proof

Glazer and Horton are cited for the uncontroversial but critical proposition that the plaintiff must prove entitlement to contractual benefits. Although they are not discussed in detail, they underpin the opinion’s repeated rejection of attempts to shift evidentiary burdens onto MetLife.

D. Alexandra H. (2019) and Bankhead: Passive Suicidal Ideation

The court cites an unpublished Eleventh Circuit decision, Alexandra H. v. Oxford Health Ins., Inc., 763 F. App’x 865 (11th Cir. 2019), along with Bankhead v. Shulkin, 29 Vet. App. 10 (Vet. App. 2017), to distinguish passive from active suicidal ideation:

Passive suicidal ideation “refers to a situation in which the patient may think about or wish for death but harbors no intent or plan to harm herself,” whereas active suicidal ideation “entails thoughts of self‑directed violence and death.”

These citations serve two purposes:

  • They provide a clear, judicially endorsed definition of “passive suicidal ideation,” a concept central to evaluating the severity of Hovan’s psychiatric condition.
  • They support the court’s conclusion that passive suicidal ideation—even if troubling—does not automatically establish work‑precluding disability, particularly where other indicators show intact functioning.

E. Forbus v. Sears Roebuck & Co. and Rule 56

The court briefly cites Forbus v. Sears Roebuck & Co., 30 F.3d 1402 (11th Cir. 1994), and Federal Rule of Civil Procedure 56(a) to confirm that it reviews summary judgment decisions de novo and that summary judgment is appropriate where there is no genuine issue of material fact and the movant is entitled to judgment as a matter of law. In the ERISA context, this rule applies as courts decide benefit disputes largely on a paper record.

V. The Court’s Legal Reasoning

A. Step One of Blankenship: Was MetLife’s Decision “De Novo Wrong”?

The pivotal inquiry was whether, looking at the administrative record afresh, the appellate court disagreed with MetLife’s decision to terminate benefits as of October 16, 2020. The court framed the period at issue as after Hovan’s discharge from PeakView, because prior to that point MetLife accepted that she was disabled.

Crucially, after October 16, 2020, the only evidence of ongoing psychiatric issues that Hovan submitted to MetLife consisted of Stevens’s therapy notes. The court’s evaluation of those notes drove the outcome.

B. Evaluation of the Medical and Therapy Evidence

1. PeakView Discharge Summary

PeakView psychiatrist Dr. Punjwani’s discharge note characterized Hovan’s prognosis as “good,” reported stable mood, absence of anxiety or depression, normal sleep and appetite, and denied active suicidal or homicidal ideation and psychotic symptoms. He concluded she was “not at imminent risk nor gravely disabled” and was “safe to discharge.”

While a “good prognosis” does not alone prove capacity to return to the stressful demands of commercial litigation, this discharge note set a baseline: as of October 16, 2020, the treating psychiatrist did not find her so impaired as to require ongoing intensive care or emergency measures.

2. Stevens’s Therapy Notes: Symptoms vs. Function

Stevens’s notes documented:

  • Fluctuating mood with episodes of depression, mania, and anxiety;
  • Occasional passive suicidal ideation described as “fleeting” and without plan or intent;
  • Hovan’s intermittent discontinuation of medications due to a belief they were unnecessary.

However, the same notes consistently recorded:

  • “Functional status” as “intact”;
  • Affect as “appropriate”;
  • Cognition as “oriented/alert”; and
  • Interpersonal functioning as “interactive.”

Stevens never opined that Hovan was unable to work nor identified specific occupational restrictions or cognitive impairments. From the court’s perspective, this was decisive: the records showed symptoms but did not show that those symptoms prevented Hovan from performing her job’s material duties.

3. Contrast with Dr. Lara’s 2019 Records

The court drew a sharp contrast between:

  • Dr. Lara’s 2019 records, which MetLife had relied on to approve initial benefits, and
  • Stevens’s 2020–2021 therapy notes.

Dr. Lara specifically documented impairments in judgment, decision‑making, interpersonal functioning, and stress tolerance—capabilities “critical” to success as a commercial litigator. Those records gave MetLife a clear rationale for finding disability at that time.

Stevens’s notes, by contrast, lacked comparable findings of impaired cognition, judgment, or work function. They did not suggest that Hovan’s symptoms were uncontrolled to the point of disabling occupational limitations. This contrast bolstered the court’s view that the absence of similar functional findings post‑October 2020 was telling.

C. Treatment of Passive Suicidal Ideation

The court candidly acknowledged that some of Stevens’s notes were “troubling” because Hovan reported passive suicidal ideation. However, anchored by the definitions drawn from Alexandra H. (2019) and Bankhead, the court emphasized:

  • The thoughts were described as “fleeting,”
  • They appeared in only a few sessions, and
  • They were passive—wishes or thoughts of death without any intent or plan.

In the face of these facts and the repeated notation that Hovan’s functional status was “intact,” the court concluded that this passive suicidal ideation “although concerning—did not prevent her from performing her duties as a commercial litigator.”

The legal significance is twofold:

  1. Passive suicidal ideation is a serious clinical sign but, without more, is not presumptively disabling under an ERISA plan’s occupational standard.
  2. Where contemporaneous clinical documentation portrays intact functioning and no acute risk, courts may treat passive suicidal ideation as insufficient to prove work‑precluding disability.

D. The Burden of Proof and “Proof of Continuing Disability”

The plan’s explicit termination clause—ending benefits when proof of continuing disability is not provided—directly interacts with the claimant’s burden of proof. The court stressed:

  • It was Hovan’s responsibility, not MetLife’s, to supply evidence that she remained unable to perform the material duties of her specialty.
  • MetLife reasonably expected some form of occupationally oriented medical opinion or clinical evidence linking continued symptoms to specific work‑related functional limitations.
  • Hovan, through counsel, declined MetLife’s invitation to submit additional evidence after receiving Dr. Ghebrendrias’s report, despite knowing MetLife considered Stevens’s notes insufficient.

By failing to fill the evidentiary gap, Hovan effectively left the record devoid of proof of continuing disability. The court therefore held that “the record she provided did not satisfy [her] burden,” and that MetLife correctly concluded she no longer met the Plan’s definition of disabled after October 2020.

E. Responses to Hovan’s Specific Arguments

1. Alleged Requirement of a Treating Provider Work‑Capacity Opinion

Hovan argued MetLife improperly required a treating provider (e.g., Stevens) to opine explicitly on her work capacity. The court rejected this, clarifying:

  • MetLife did not impose a specific “treating‑physician‑opinion” requirement.
  • It merely required “evidence establishing Hovan’s inability to perform her occupational duties as a commercial litigator.”
  • As the Plan and ERISA law place the burden on the claimant, it was proper for MetLife to insist on sufficient evidence of inability to work—even if it took the form of functional assessments from providers.

In other words, the objection failed because it mischaracterized MetLife’s demand; the insurer had asked for functional proof, not a particular formal statement.

2. Reliance on a File‑Review Psychiatrist

Hovan further criticized MetLife for relying on a file‑reviewing psychiatrist (Dr. Ghebrendrias) who she claimed “gave no consideration to the duties or demands of the occupation.” The court answered this argument in several steps:

  1. File reviews are permissible: The court reiterated that, under Blankenship, using independent “file” reviewers absent other troubling circumstances does not render a decision arbitrary and capricious.
  2. Report addressed key functional domains: Although Dr. Ghebrendrias did not explicitly tie her analysis to “commercial litigator” job duties, she discussed symptoms and functioning broadly and noted specifically there was no evidence of “lack of motivation” or “impairment in insight and judgment”—traits obviously essential to practicing complex litigation.
  3. The burden does not shift to MetLife: The court characterized Hovan’s challenge as an attempt to shift the burden of proof:
    “The crux of the benefits termination was the insufficiency of therapist Ms. Stevens’s notes to establish Hovan’s continued disability. The burden was not on MetLife to provide a report conclusively ruling out that Hovan was disabled.”
    Thus, even if one were to accept that Dr. Ghebrendrias’s report was not occupationally granular, that would not salvage the claim; the core problem remained the claimant’s failure to produce sufficient affirmative evidence of disability.

F. Stopping at Step One of Blankenship

Having concluded that MetLife’s decision was not de novo wrong, the court properly ended the Blankenship analysis at Step 1. It did not:

  • Address whether MetLife’s discretionary authority triggered arbitrary‑and‑capricious review (Step 2),
  • Analyze whether MetLife’s decision was “reasonable” under a deferential standard (Step 3), or
  • Weigh any structural conflict of interest (Steps 4–6).

This reinforces the practical point that if the court believes the denial is correct under the strictest (de novo) standard, additional layers of deference or conflict analysis are unnecessary.

VI. Complex Concepts Simplified

A. “Own Occupation” vs. “Any Occupation” Disability

Disability plans frequently distinguish:

  • Own Occupation: You are disabled if you cannot perform the material duties of your regular job or specialty (here, commercial litigation).
  • Any Occupation: You are disabled only if you cannot perform the duties of any job for which you are reasonably qualified by education, training, or experience.

Under this Plan and at the time in question, the standard was “Own Occupation.” This is typically more favorable to claimants than an “Any Occupation” standard, but still requires proof that symptoms translate into an inability to do the actual work of that occupation.

B. De Novo vs. Arbitrary‑and‑Capricious Review

In simple terms:

  • De novo review asks: “Is this decision correct?” The court gives no deference; it decides the question independently based on the record.
  • Arbitrary‑and‑capricious (or abuse‑of‑discretion) review asks: “Is this decision reasonable?” Even if the court might have decided differently, it will uphold the administrator’s decision if it is within a range of reasonable outcomes.

Because the court found MetLife’s decision correct even under the more demanding de novo standard, it never needed to apply the more lenient arbitrary‑and‑capricious standard.

C. Passive vs. Active Suicidal Ideation

Clinically and legally:

  • Passive suicidal ideation: Thoughts such as “I wish I were dead” or “life is not worth living,” but no plan or intent to act.
  • Active suicidal ideation: Thoughts accompanied by intent to self‑harm, often with a concrete plan or preparation.

Courts view active suicidal ideation as a far more acute risk factor that may strongly support disability. Passive suicidal ideation is still serious but does not automatically demonstrate that a person cannot function in their job, especially where other measures of functioning are intact.

D. Summary Judgment in ERISA Cases

Summary judgment is granted if there is “no genuine dispute as to any material fact” and the movant is entitled to judgment as a matter of law. In ERISA benefit cases:

  • The “facts” are usually those contained in the administrative record.
  • Cross‑motions for summary judgment effectively ask the court to decide the case on that record, applying the appropriate standard of review.
  • Because the record is closed, the key question is often not factual disputes but how to interpret the existing evidence under plan terms.

VII. Impact and Practical Implications

A. Doctrinal Impact (Within the Eleventh Circuit)

Although designated “Not for Publication” and thus non‑precedential, the opinion is a clear and recent example of how the Eleventh Circuit:

  • Applies the Blankenship framework, and in particular, stops at Step 1 when it finds no de novo error.
  • Interprets the claimant’s burden to prove continuing disability under a plan that conditions ongoing payment on continued proof.
  • Assesses mental‑health claims with a strong focus on functional, not purely symptomatic, evidence.

Future courts and practitioners in the circuit are likely to cite or analogize to its reasoning, even if not as binding precedent, when faced with similar records (i.e., therapy notes documenting symptoms but also “intact” functioning and no explicit work‑capacity opinions).

B. Implications for Claimants and Their Counsel

Several lessons emerge for ERISA claimants, especially those with mental health claims:

  1. Provide Functional, Occupationally Focused Evidence
    Simply submitting therapy notes or psychiatric progress notes that describe symptoms is often not enough. Claimants should:
    • Ask treating providers to connect symptoms explicitly to the demands of the claimant’s job.
    • Seek written functional assessments or narrative reports addressing concentration, decision‑making, judgment, stress tolerance, interpersonal functioning, and ability to perform key tasks.
    • Avoid leaving the record with only boilerplate descriptors such as “functional status: intact” if they contend they cannot work.
  2. Do Not Ignore Requests to Supplement the Record
    When an insurer provides an adverse expert report and invites additional evidence, ignoring that invitation can be fatal. Courts typically confine their review to the administrative record; failing to supplement at that stage may foreclose presenting key evidence later.
  3. Recognize the Legal Meaning of Passive Suicidal Ideation
    Passive suicidal thoughts are clinically important but, in isolation, may not satisfy a plan’s disability standard. To support a disability claim, they should be placed in context: frequency, severity, impact on daily functioning, need for intensive care, and how they impair the ability to work safely and reliably.
  4. Continuing Disability Is Not Presumed from Past Disability
    Prior approval of benefits—especially for mental health conditions—does not guarantee continuation. Claimants must continually document the persistence (or recurrence) of work‑precluding limitations as required by plan terms.

C. Implications for Plan Administrators and Insurers

For administrators like MetLife, the opinion:

  • Endorses using file‑reviewing physicians to assess ongoing disability, particularly where there is no compelling reason to require an in‑person exam.
  • Supports terminating benefits when the record shows stabilized symptoms, intact functioning, and no documented occupational limitations, especially if the plan explicitly conditions benefits on providing proof of continuing disability.
  • Highlights the importance of:
    • Clearly articulating in decision letters what evidence is lacking;
    • Inviting additional submissions from the claimant;
    • Documenting attempts to obtain information from treating providers.

D. Implications for Treating Clinicians

The decision underscores how therapists’ and psychiatrists’ documentation is read in the legal context:

  • Repeated notations of “functional status: intact,” “oriented/alert,” and “appropriate affect” can be construed as inconsistent with work‑precluding impairment, particularly for cognitively demanding occupations.
  • Failure to address occupational functioning directly leaves courts and insurers to infer that the patient may be able to work despite symptoms.
  • Where clinicians believe a patient cannot safely or reliably perform job duties, they should consider explicitly stating this, explaining why, and tying opinions to specific observations and clinical findings.

E. Mental‑Health Disability Jurisprudence

As a matter of broader disability jurisprudence under ERISA, this case:

  • Reinforces a trend toward emphasizing functional capacity over symptom presence.
  • Demonstrates judicial caution in equating mental‑illness diagnoses—even serious ones like bipolar disorder—with occupational disability without clear evidence of work‑precluding limitations.
  • Signals that courts will scrutinize mental‑health records for internal consistency: a mix of reported symptoms with documented intact functioning will often support benefit termination or denial.

VIII. Conclusion

Hovan v. Metropolitan Life Insurance Company illustrates a central principle in ERISA mental‑health disability litigation: symptoms alone do not establish disability; functional and occupational impairment must be proved. The Eleventh Circuit, applying the Blankenship framework, found that MetLife’s termination of benefits was not de novo wrong because the post‑October 2020 record—dominated by therapy notes documenting intact functioning, a “good prognosis” on discharge from partial hospitalization, and no occupational restrictions—did not meet the claimant’s burden of demonstrating continuing disability as a commercial litigator.

The opinion clarifies that:

  • ERISA claimants must continually substantiate disability, especially when plan terms make benefits conditional on ongoing proof.
  • Passive suicidal ideation, while serious, does not automatically equate to occupational disability in the absence of broader functional impairment.
  • Plan administrators may legitimately rely on file‑reviewing experts and are not required to disprove disability when claimants fail to affirmatively prove it.

For practitioners, administrators, and clinicians, the case is a detailed roadmap of how appellate courts may parse mental‑health records, weigh functional findings, and apply the burden of proof in ERISA disability disputes. Even as an unpublished opinion, its reasoning is likely to be influential in shaping arguments and documentation practices in future mental‑health disability claims.