Coffman v. Metropolitan Life Insurance Co., No. 02-2128, 2003 WL 22293610 (4^th Cir. 2003)

Employee sued employer under ERISA. US District Court for Southern District of West Virginia Judge Haden II granted summary judgment for employer. Employee appealed. Employee claimed CFS, chronic fatigue syndrome, was the cause of the disability. The Court per curium affirmed. The Court held (1) there was no abuse of discretion by administrator for denying benefits, decision being deliberate and reasoned (2) there was a lack of consensus diagnosis and (3) lack of objective medical support for claimed disability and (4) there was videotaped evidence showing claimant had exaggerated illness.