The U.S. District Court for the Central District of California recently granted long-term disability (“LTD”) benefits to Plaintiff Hettihewage Dharmasena following an ERISA appeal in Dharmasena v. Metropolitan Life Insurance Co., __ F. Supp. 3d __, 2025 WL 1563970 (C.D. Cal. May 29, 2025). This decision offers important guidance on how courts evaluate disability claims under de novo review, address disputes over the onset of disability, and treat claims for retroactive disability periods.

Mr. Dharmasena was employed as a technical professional covered under a group LTD policy administered by MetLife. After developing progressive orthopedic and neurological impairments, including degenerative disc disease and chronic pain, he stopped working on February 4, 2022, and submitted a claim for LTD benefits. MetLife denied the claim, asserting that his disability began on February 7, 2022—after his February 4 termination—making him ineligible for benefits because he was not “in active service” when his disability commenced.

Under the plan, Mr. Dharmasena was required to demonstrate that, due to sickness or injury, he was unable to perform the material and substantial duties of his regular occupation while still covered under the policy. Despite extensive medical documentation showing significant functional limitations, MetLife determined that he was not disabled within the meaning of the plan and denied the claim. On appeal, MetLife upheld its denial, maintaining that the evidence did not establish a qualifying disability prior to the termination date.

Mr. Dharmasena then filed suit under ERISA § 502(a)(1)(B), challenging both MetLife’s interpretation of the plan and its evaluation of the evidence. The court applied a de novo standard of review, meaning it independently assessed the administrative record without deference to MetLife’s decision. Under this standard, the burden remained on the plaintiff to prove by a preponderance of the evidence that he was both disabled and covered under the plan. The court found that the medical evidence—physician notes, diagnostic findings, and consistent reports of pain and functional decline—demonstrated that Mr. Dharmasena was disabled within the meaning of the policy prior to his termination.

Significantly, the court addressed the treatment of retroactive disability periods. It held that an ERISA claimant may establish entitlement to LTD benefits for past periods of disability if the medical evidence shows that he was disabled during those times, even if the claim is filed later or the claimant was not under continuous medical care. Rejecting MetLife’s argument that the absence of ongoing treatment during the retroactive period defeated the claim, the court emphasized that what matters is not continuous physician contact, but the totality of reliable medical evidence showing functional incapacity during the relevant timeframe.

The court’s analysis is particularly important for claimants who may be unable to promptly submit claims due to the very nature of their impairments. The decision confirms that ERISA permits retroactive awards where credible, contemporaneous medical documentation demonstrates disability—even if gaps in treatment exist. The ruling reinforces that a lack of ongoing visits during the claimed period does not necessarily negate disability; the key question is whether the record, taken as a whole, supports that the claimant met the policy’s definition of disability.

By awarding LTD benefits to Mr. Dharmasena, the court reaffirmed the central role of objective medical evidence and fair evaluation in ERISA litigation. The case underscores that plan administrators cannot deny valid claims based on hypertechnical timing arguments or procedural formalities when the medical record clearly establishes disability during the coverage period. For ERISA claimants and practitioners, Dharmasena provides clear and persuasive authority supporting retroactive disability determinations grounded in the substance of the evidence rather than rigid procedural timelines.