The Worker's Compensation Act compensates workers who are injured on the job and miss work due to that injury. The Act does not however replace a worker's full wage while he is recovering from a work related injury.
Kathleen Bernardo was employed by American Airlines as a Manager of Airport Services. Bernardo was diagnosed with aplastic anemia and was treated with cyclosporin A and prednisone. Bernardo sought long-term disability benefits under the Plan for which MetLife was the administrator. Bernardo's claim for long-term disability benefits included a letter from Dr. Rice, Bernardo's treating physician, stating that she was unable to work "due to severe pansytopena and side effects of medication, including profound fatigue, tremors, and nausea." Based on this information, MetLife determined that Bernardo was totally disabled and approved long-term disability benefits. However, MetLife later re-evaluated Bernardo's claim and decided to deny Bernardo's long-term disability benefits because the records "did not substantiate that she was totally disabled." Bernardo sued under the Employee Retirement Income Security Act of 1974 (ERISA).