United States Court of Appeals 

For the First Circuit 

No. 17-1428 

DIONISIO SANTANA-DÍAZ, 

Plaintiff, Appellant, 

v. 

METROPOLITAN LIFE INSURANCE COMPANY, 

Defendant, Appellee, 

SHELL CHEMICAL YABUCOA, INC.; BUCKEYE CARIBBEAN TERMINAL, LLC, 

f/k/a Shell Chemical Yabucoa, Inc.; IKON GROUP, INC.; JOHN DOE; 

JANE DOE; XYZ ADMINISTRATOR, INC., 

Defendants. 

APPEAL FROM THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

[Hon. Aida M. Delgado-Colón, U.S. District Judge] 

Before 

Howard, Chief Judge, 

Thompson and Barron, Circuit Judges. 

Efraín Maceira-Ortiz for appellant. 

Frank Gotay-Barquet, with whom Gotay & Pérez, P.S.C. was on 

brief, for appellee. 

March 29, 2019 
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HOWARD, Chief Judge. This case concerns the denial of 

long-term disability ("LTD") benefits for Plaintiff-Appellant 

Dionisio Santana-Díaz ("Santana") under his employee welfare 

benefit plan ("Plan"). After the Plan's administrator, DefendantAppellee Metropolitan Life Insurance Co. ("MetLife"), denied 

Santana's LTD benefits claim, Santana brought suit under the 

Employee Retirement Income Security Act of 1974, as amended 

("ERISA"), 29 U.S.C. §§ 1001-1461. Applying the parties' agreedupon standard of review, the district court granted judgment on 

the administrative record to MetLife. For the reasons discussed 

below, we AFFIRM. 

I. 

We begin with the basic facts leading to August 2011, 

when MetLife denied Santana's claim for LTD benefits under the 

Plan through his employer, Shell Chemical Yabucoa, Inc. Shell 

Chemical employed Santana as an accountant for over 25 years. 

Santana submitted a disability claim form for disabilities that 

arose in late 2007. MetLife approved the claim, which was for 

disabilities arising from a mental disorder or illness due to major 

depression. MetLife paid Santana benefits under the Plan's limited 

24-month benefit duration period, effective as of November 2008. 

Over the course of 2010 and 2011, Santana and MetLife 

exchanged a series of correspondence. MetLife sent Santana a 

letter in April 2010 informing him that his limited disability 
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benefits would expire that November unless MetLife received 

objective medical information establishing that he was eligible 

for LTD benefits. In November 2010, MetLife sent Santana another 

letter, this time terminating his disability benefits on the ground 

that his disability was a limited-benefit condition.1 MetLife 

further explained that "based on review of the information 

submitted for [Santana's] non psychiatric medical issues, the 

medical documentation does not support the inability for [Santana] 

to perform [his] job which is sedentary in nature or any exclusion 

to the 24 month limitation." The letter also advised Santana of 

his right to appeal the denial of benefits with MetLife, which he 

proceeded to do in April 2011. Santana explained in his appeal 

that the combination of mental and physical conditions rendered 

him completely disabled from any employment. 

In its review of Santana's appeal, MetLife consulted two 

independent physicians, one for psychiatry and one for 

occupational medicine. That review resulted in MetLife's August 

19, 2011, letter denying Santana's claim ("MetLife's Final 

Decision"). MetLife's Final Decision shows that in early June 

2011, the occupational medicine consultant spoke with Santana's 

primary care physician, Dr. Catoni. According to MetLife, "Dr. 

 1 The Plan excluded six physical conditions from the 24-month 

benefit limit, including, as relevant here, radiculopathies -- 

defined in the Plan as "[d]isease[s] of the peripheral nerve roots 

supported by objective clinical findings of nerve pathology." 
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Catoni indicated to the consultant that [Santana's] main problems 

were psychological." Dr. Catoni also told the consultant that 

Santana could not walk long distances due to diabetic neuropathy, 

and that arthritis in the shoulders limited Santana's overhead 

movement. The consultant noted that although Dr. Catoni stated 

this, the clinical data provided did not confirm the presence of 

lumbosacral neuropathy or any diabetic peripheral neuropathy. 

Furthermore, "the consultant indicated there were no physical 

exams, office visits, or any clinical findings provided in the 

records that supported that these conditions were causing any 

physical impairment." Consequently, the consultant concluded that 

the medical records did not support a limited benefit exclusionary 

diagnosis of radiculopathies or other enumerated conditions. 

On June 9, 2011, MetLife faxed a copy of the consultants' 

reports to Santana's doctors, requesting that they submit any 

comments on the reports. Dr. Catoni responded, expressing concern 

about the occupational medicine consultant's report, which stated 

that there was no evidence of diabetic polyneuropathy. He noted 

his office record from February 25, 2011, in which the condition 

was "well documented," and he accordingly sent additional records 

to MetLife. MetLife directed the occupational medicine consultant 

to review the file further, after which the consultant stated that 

"he still had no physical examinations, objective findings or 

office visit reports that supported that the diagnosis of diabetic 
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peripheral neuropathy led to physical impairment and consequently 

restrictions and limitations on work abilities." 

Subsequently, MetLife's Final Decision letter denied 

Santana's claim. In regard to Santana's doctors' diagnoses of 

diabetic polyneuropathy and other conditions, the letter explained 

that "although your physicians indicate [that] you have these 

diagnoses . . . [t]he diagnosis of a medical condition alone does 

not support an inability to function or support a disabling 

condition." Thus, in line with its consultant's findings, MetLife 

concluded that "the medical information provided is limited and 

does not support that any of these conditions alone or in 

combination would preclude [Santana] from performing [his] own 

sedentary job as an accountant." 

After exhausting the Plan's administrative remedies, 

Santana began this action on August 18, 2013, filing suit under 

ERISA, 29 U.S.C. § 1132(a)(1)(B), against MetLife, and others, in 

the federal district court for Puerto Rico. Santana claimed that 

MetLife unreasonably, arbitrarily, and capriciously denied him LTD 

benefits under the Plan. In May 2014, MetLife moved for summary 

judgment. The district court granted summary judgment in MetLife's 

favor in January 2015, holding that the Plan's statute of 

limitations barred Santana's complaint. Santana appealed the 

district court's order, and, in March 2016, we reversed, holding 

that the contractual statute of limitations did not apply because 
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MetLife failed to advise Santana of the deadline for seeking 

judicial review of its decision. Santana-Díaz v. Metro. Life Ins. 

Co., 816 F.3d 172 (1st Cir. 2016). In late 2016, back in the 

district court, the parties cross-moved for judgment on the 

administrative record. In March 2017, the district court found 

that MetLife acted reasonably, and thus granted MetLife's motion. 

The district court entered final judgment the next day, and Santana 

timely appealed. 

II. 

A. 

We review the district court's judgment on the 

administrative record de novo. Buffonge v. Prudential Ins. Co. of 

Am., 426 F.3d 20, 28 (1st Cir. 2005). 

Here, we must determine whether MetLife's denial of 

Santana's LTD benefits was "arbitrary, capricious or an abuse of 

discretion." See id. To that end, we consider the text of the 

ERISA plan and the plain meaning of the words used therein, which 

cabin the plan's administrator's discretion. See Colby v. Union 

Sec. Ins. Co. & Mgmt. Co. for Merrimack Anesthesia Assocs. Long 

Term Disability Plan, 705 F.3d 58, 65 (1st Cir. 2013). In such 

plans, "the employer (or an insurance company that stands in the 

employer's shoes) must spell out exclusions distinctly." Id. at 

65-66. 
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Further, under ERISA, a disability benefits denial must 

"set[] forth the specific reasons for such denial, written in a 

manner calculated to be understood by the participant." 29 U.S.C. 

§ 1133. A plan administrator's decision "must be reasoned and 

supported by substantial evidence" -- "[i]n short, [it] must be 

reasonable." Ortega-Candelaria v. Johnson & Johnson, 755 F.3d 13, 

20 (1st Cir. 2014) (internal quotation marks omitted) (citing 

Colby, 705 F.3d at 62). If the plan administrator's interpretation 

of the plan is reasonable, then it "will not be disturbed." 

Conkright v. Frommert, 559 U.S. 506, 521 (2010) (quoting Firestone 

Tire & Rubber Co. v. Bruch, 489 U.S. 101, 111 (1989)). In deciding 

whether an interpretation of a plan is reasonable, several other 

circuits have advanced various specific standards, including 

looking to the consistency of an administrator's construction with 

the plain meaning of the plan or looking to several guiding 

factors. See D&H Therapy Assocs., LLC v. Bos. Mut. Life Ins. Co., 

640 F.3d 27, 37-38 (1st Cir. 2011) (summarizing standards in the 

Second, Third, Fourth, Fifth, Seventh, Eighth, Ninth, and D.C. 

circuits). We consider these standards instructive but do not 

adopt them or any specific guiding factors. Id. at 38. 

Santana highlights several purported deficiencies with 

the MetLife claims administrators' review and denial of his LTD 

benefits claim. First, Santana argues that MetLife failed to 

consider the conditions documented by Santana's treating 
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physician, Dr. Catoni, and his physiatrist,2 Dr. Maldonado. 

Second, he claims that MetLife inconsistently interpreted the 

Plan, to his detriment. Third, he argues that MetLife denied his 

claim without providing him with sufficient information regarding 

the requisite showing to qualify for LTD benefits. Finally, 

Santana argues that MetLife acted in an arbitrary and capricious 

manner by adding a "functional limitations" criterion as an 

additional ground for exclusion of benefits. We address each of 

Santana's challenges in turn. 

B. 

Santana chiefly argues that the Plan Administrator's 

denial of LTD benefits to Santana was arbitrary and capricious 

because the administrator cherry-picked evidence it preferred 

while ignoring significant contrary evidence. In support, Santana 

relies largely on the discussion in Cowern v. Prudential Insurance 

Co. of America, 130 F. Supp. 3d 443 (D. Mass. 2015) (denying cross 

motions for summary judgment in ERISA action challenging 

administrator's decision to terminate benefits). In Cowern, the 

district court concluded that the administrator acted arbitrarily 

and capriciously by relying on selective comments in a doctor's 

 2 Physiatrists, specialists in physical medicine and 

rehabilitation, treat a range of conditions focusing on the 

musculoskeletal system. 
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report to deny the claim, ignoring other statements in the report 

that tended to support the claim. Id. at 464-66. 

The Supreme Court has recognized such cherry-picking as 

a factor to support setting aside a plan administrator's 

discretionary decision. See Metro. Life Ins. Co. v. Glenn, 554 

U.S. 105, 118 (2008) (affirming the Sixth Circuit's reversal of 

the plan administrator's decision, in part because "MetLife had 

emphasized a certain medical report that favored a denial of 

benefits, had deemphasized certain other reports that suggested a 

contrary conclusion, and had failed to provide its independent 

vocational and medical experts with all of the relevant 

evidence."). Other circuits have done the same. See, e.g., Love 

v. Nat'l City Corp. Welfare Benefits Plan, 574 F.3d 392, 397-98 

(7th Cir. 2009) ("While plan administrators do not owe any special 

deference to the opinions of treating physicians . . . they may 

not simply ignore their medical conclusions or dismiss those 

conclusions without explanation." (internal citation omitted)); 

Winkler v. Metro. Life Ins. Co., 170 F. App'x 167, 168 (2d Cir. 

2006) ("An administrator may, in exercising its discretion, weigh 

competing evidence, but it may not, as MetLife did here, cherrypick the evidence it prefers while ignoring significant evidence 

to the contrary."). 

Here, assuming without deciding that an insurer's 

cherry-picking of favorable evidence alone may be grounds for 
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reversal, Santana cannot show that MetLife was guilty of that in 

processing his claim. Santana asserts that MetLife cherry-picked 

evidence and failed to consider the conditions documented by Dr. 

Catoni and Dr. Maldonado. Santana concludes that, contrary to 

MetLife's Final Decision, his medical records include "objective 

clinical findings" that he had a diagnosis of radiculopathies. 

This argument fails because MetLife did in fact consider the 

evidence that Santana alleges that it overlooked, but MetLife 

determined that the evidence did not satisfactorily prove that 

Santana was eligible for LTD benefits under the Plan. 

Santana first suggests that MetLife ignored two progress 

notes from Dr. Catoni, one sent to MetLife on August 5, 2010, and 

the second dated February 25, 2011, both of which included a 

diagnosis of polyneuropathy, among other conditions. The record 

belies this contention. As MetLife's Final Decision states, 

MetLife's consultant reviewed Dr. Catoni's progress notes and "he 

found no objective data from [those] notes to support functional 

limitations." This is the crux of the matter: Even if Dr. Catoni's 

notes established that Santana suffered from polyneuropathy, 

MetLife concluded that the records "failed to support any 

restrictions or limitations based on this diagnosis." 

Next, Santana draws our attention to a late-2010 record 

from Dr. Maldonado that MetLife purportedly ignored regarding an 

electromyogram ("EMG") -- but like Dr. Catoni's report, this record 
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is also noted in MetLife's Final Decision. Specifically, MetLife's 

Final Decision letter shows that its review of Santana's 

administrative appeal included "medical records from Dr. Maldonado 

which included EMG/NCS studies dated November 15, 2010." MetLife's 

consultant's report notes the November 2010 EMG nerve study with 

Dr. Maldonado, stating somewhat cryptically: "EMG Nerve Study; 

Peripheral Motor Sensory Polyneuropathy; Right Femoral Nerve 

Lesion." MetLife's letter does not state what its consultants 

made of the medical records that Dr. Maldonado provided, 

particularly the November 2010 EMG. 

According to Santana, the November 2010 EMG study shows 

that Dr. Maldonado had diagnosed him with "Peripheral Motor Sensory 

Polyneuropathy; Right Femoral Nerve Lesion," which constitutes 

objective clinical findings of radiculopathies. He argues that 

this "finding" sustains Dr. Catoni's findings of diabetic 

polyneuropathy in his progress notes. But his position takes too 

much liberty with the evidence at hand. Despite the repeated 

references in the briefing, Santana does not actually identify the 

EMG in the record. Rather, he points to the notation in MetLife's 

consultant's report. While Santana views this as objective 

clinical findings of radiculopathies, MetLife was not so 

persuaded. It is not clear from the face of that record what the 

noted items mean, much less what they intend to show or prove. 
- 12 - 

Ironically, Santana's highlighting of Dr. Catoni's 

statement and the EMG notation in the consultant's report 

undermines his argument by drawing attention to MetLife's 

consideration of these documents. MetLife's conclusion that these 

records failed to show that Santana was physically disabled under 

the Plan is reasonably supported by the record and thus not 

arbitrary or capricious cherry-picking. 

C.

Next, Santana asserts that MetLife also acted 

arbitrarily by treating medical evidence inconsistently. In 

support, he cites a June 2013 letter from MetLife regarding the 

reinstatement of Santana's life insurance benefits. That letter 

stated that "[t]he conditions that have been considered in the 

coverage reinstatement were major depressive disorder, 

degenerative disc disease, diabetes mellitus type 2, diabetic 

polyneuropathy, chronic pain of shoulder, high blood pressure, 

asthma and hypothyroidism." From this statement noting that 

MetLife considered, among other things, diabetic polyneuropathy to 

reinstate life insurance benefits, Santana concludes that MetLife 

did not consistently apply and interpret the conditions to qualify 

for LTD benefits. 

This is a false equivalence. Contrary to Santana's 

assertion, there is no evidence that the criteria to qualify for 

life insurance benefits is the same as the criteria to qualify for 
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LTD benefits. Life insurance is not included in the Plan's 

coverage for LTD benefits, further suggesting that the two involve 

separate inquiries. Because there is no indication that MetLife 

reinstated Santana's life insurance coverage because it found him 

to be disabled due to diabetic polyneuropathy, Santana has failed 

to identify any inconsistent treatment by MetLife on the disability 

determination. Accordingly, the comparison to his life insurance 

coverage offers no basis to find MetLife's disability 

determination unreasonable. 

D. 

We turn now to the dispute over the required proof of 

Santana's disability. The Plan states that "to receive benefits 

under This Plan, you must provide to us at your expense, and 

subject to our satisfaction," documents showing proof of 

disability. Santana argues that MetLife failed to provide him 

with sufficient information regarding the requisite showing to 

qualify for LTD benefits. To that end, he claims that the phrase 

"to our satisfaction" is ambiguous and is thus procedurally flawed 

because it does not provide sufficient notice to Santana of what 

constitutes satisfactory objective evidence. Ultimately, this 

assertion rings hollow. 

A plan administrator is entitled to define ambiguous 

terms regarding proof of disability so long as its interpretation 

is reasonable. See Pralutsky v. Metro. Life Ins. Co., 435 F.3d 
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833, 839 (8th Cir.), cert. denied, 549 U.S. 887 (2006) (holding 

that where a plan does not define the "proof" or "documentation" 

sufficient to establish disability, it was not unreasonable for 

MetLife to interpret the plan to require objective evidence). 

MetLife told Santana that he had to submit current 

objective medical information that would establish that his 

condition qualified him for LTD benefits under the Plan. MetLife's 

Final Decision also emphasized that a diagnosis of a physical 

condition does not automatically entitle Santana to benefits under 

the Plan. In other words, MetLife required two types of objective 

evidence: (1) to establish a qualifying condition, such as 

radiculopathies, and (2) to show that the condition caused Santana 

to be disabled under the Plan. Santana failed to do so. MetLife's 

Final Decision explained that the evidence provided lacked any 

"physical examinations, objective findings or office visit reports 

that supported that the diagnosis of diabetic peripheral 

neuropathy . . . would preclude [Santana] from performing [his] 

sedentary job as an accountant." 

Santana's attempt now to characterize the plain language 

of the claims process -- language that the Plan expressly gave 

MetLife the discretion to interpret -- as procedurally defective 

is unconvincing. We find no abuse of discretion here because 

MetLife had the discretion to assess the sufficiency of proof 
- 15 - 

offered, and the objective evidence sought was reasonable to 

determine Santana's eligibility for LTD benefits under the Plan. 

E. 

Santana's last challenge posits that MetLife acted 

arbitrarily and capriciously by considering the functional 

limitations of his condition. Considering functional limitations 

in connection with a physical disability claim, however, does not 

constitute an arbitrary additional criterion to allow exclusion 

from LTD benefits. On the contrary, "[w]hen certain illnesses do 

not 'lend themselves to objective clinical findings,' the proper 

approach is to consider 'the physical limitations imposed by the 

symptoms of such illnesses [that] do lend themselves to objective 

analysis.'" Al-Abbas v. Metro. Life Ins. Co., 52 F. Supp. 3d 288, 

297 (D. Mass. 2014) (quoting Boardman v. Prudential Ins. Co. of 

Am., 337 F.3d 9, 17 n.5 (1st Cir. 2003)). Furthermore, the 

discussion of Santana's functional limitations points to the 

threshold question of whether he is disabled under the Plan. 

The Plan's definition of "disability" covers conditions 

that prevent an individual from making 80 percent of pre-disability 

earnings in one's occupation for any employer in the local economy. 

Functional limitations caused by an alleged physical disability 

are reasonably part and parcel of the disability assessment. 

Therefore, MetLife did not act arbitrarily by considering the 
- 16 - 

presence (or absence) of such functional limitations in assessing 

whether Santana was disabled under the Plan. 

III. 

On this record, MetLife's decision to deny LTD benefits 

to Santana based on physical disability was reasonable and 

substantially supported by the evidence at hand. The 

administrative record shows a reasonably thorough claims process 

that included communications between not just MetLife and Santana, 

but also between the medical consultants and attending physicians 

involved in Santana's care and assessment. 

For the foregoing reasons, we AFFIRM the district 

court's order granting judgment to MetLife.