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Suter v. Metropolitan Life Insurance Co.

United States District Court, W.D. Virginia, Charlottesville Division

June 9, 2016

CAROLYN D. SUTER, Plaintiff,



         This matter is before the Court for resolution of motions regarding the permissibility and scope of discovery. On April 11, 2016, Defendant Metropolitan Life Insurance Company (“MetLife”) moved to modify the Court’s Pretrial Order, ECF No. 11, and to hold a scheduling conference. ECF No. 12. In its motion, MetLife notified the Court that the parties disagreed as to whether the case could be resolved by review of only the Administrative Record, ECF No. 8, or whether additional discovery outside of the Administrative Record should be permitted. Following a scheduling conference call held on April 13, the Court took MetLife’s motion under advisement and ordered the parties to submit briefing on the permissible scope of discovery. ECF No. 15. The parties each submitted opening and response briefs, ECF Nos. 16, 18-20, and Plaintiff Carolyn D. Suter moved to conduct discovery outside of the Administrative Record, ECF No. 17.

         I. Facts and Procedural History

         This case concerns Suter’s claim for coverage under an insurance policy that is governed by the Employment Retirement Income Security Act of 1974, as amended, 29 U.S.C. § 1001, et seq. (“ERISA”). Through Suter’s employment with the General Electric Company (“GE”), her husband was insured under GE’s Dependent Accidental Death & Dismemberment Insurance (“the Plan”), with Suter the named beneficiary under her husband’s policy. Compl. ¶¶ 5-6, ECF No. 1. Benefits payable under the Plan are funded by a group policy issued by MetLife to GE, and MetLife administers claims under the Plan in accordance with ERISA. Answer ¶¶ 1, 6. On January 21, 2015, Suter’s husband died after sustaining injuries in a fall two days earlier. Compl. ¶ 7. On March 3, 2015, Suter presented MetLife with a claim for benefits payable to her under the Plan as a result of her husband’s death. Id. ¶ 8. MetLife denied Suter’s claim initially and on appeal after finding that Mr. Suter’s death was not covered under the terms of the Plan, citing language in the GE employee benefits handbook (“the Handbook”). Id. ¶¶ 8, 10-12. Specifically, MetLife considered two provisions in the Handbook: Section 1.1.5, which states that “death benefits are paid if you die from an injury within 180 days of the accident that caused the injury, or within 3 years of the accident if your death is solely and directly a result of the accident, ” and Section 1.1.6, which states that “[b]enefits under [the Plan] are not paid for losses contributed or caused by: . . . [d]isease or medical or surgical treatment of such disease . . . [p]hysical or mental impairment or medical or surgical treatment of such impairment.” Administrative Record (“R.”) 112-13. MetLife observed that Mr. Suter’s death certificate listed cardiac decompensation, hip fracture, and humerus fracture as the cause of death and noted that congestive heart failure and kidney injury contributed to his death. Id. at 113. MetLife determined that Mr. Suter’s death was not covered because it “was contributed to by existing medical conditions and is not considered the direct and sole result of an accidental injury.” Id.

         Suter commenced this action on January 21, 2016, asserting claims for recovery of Plan benefits and breach of fiduciary duty, as well as seeking attorney’s fees, costs, and expenses.[1] Id. ¶¶ 17-32. MetLife filed its Answer on February 19, asserting nine affirmative defenses[2] in addition to denying Suter’s claims. Answer 4-7. The parties had a Rule 26(f) conference and on March 24 submitted a joint report of their planning meeting. In their report, the parties acknowledged their disagreement over the availability of traditional discovery and, in the event the Court permits discovery, the potential pre-trial deadlines. ECF No. 9. The Court entered a Pretrial Order on March 30, setting forth a schedule and provisions for discovery. ECF No. 11, at 1, 4. On April 7, Suter sent interrogatories and requests for production to MetLife. Apps. to Pl. Br., ECF Nos. 18-1 to 18-3. The parties then filed the instant motions and submitted briefing on the scope and propriety of discovery. ECF Nos. 12, 16-20.

         II. Discussion

         A. Improper Denial of Benefits

         In a claim for review of an ERISA plan administrator’s coverage determination, a court applies an abuse of discretion standard of review if “the benefit plan at issue vests the administrator with discretionary authority.” Helton v. AT&T Inc., 709 F.3d 343, 351 (4th Cir. 2013). Here, the parties agree that an abuse of discretion standard is appropriate.[3] Pl. Br. 5, ECF No. 18. Under this standard of review, a court generally will not consider evidence outside of the administrative record prepared by the plan administrator. Helton, 709 F.3d at 352. This is not an absolute bar, however. In Helton, the Fourth Circuit determined that evidence extrinsic to the administrative record may be considered by the reviewing court if that evidence (1) is necessary to assess the factors that are relevant to whether a plan administrator abused its discretion, as set out in Booth v. Wal-Mart Stores, Inc. Associates Health & Welfare Plan, 201 F.3d 335 (4th Cir. 2000), and (2) was known to the plan administrator at the time it rendered its benefits determination. Helton, 709 F.3d at 352-56.

         In Booth, the Fourth Circuit stated that a court’s review of an ERISA coverage determination for abuse of discretion requires evaluation of the following nonexclusive factors:

(1) the language of the plan; (2) the purposes and goals of the plan; (3) the adequacy of the materials considered to make the decision and the degree to which they support it; (4) whether the fiduciary’s interpretation was consistent with other provisions in the plan and with earlier interpretations of the plan; (5) whether the decisionmaking process was reasoned and principled; (6) whether the decision was consistent with the procedural and substantive requirements of ERISA; (7) any external standard relevant to the exercise of discretion; and (8) the fiduciary’s motives and any conflict of interest it may have.

201 F.3d at 342-43. As the Helton court observed, extrinsic evidence may be necessary to evaluate these factors, particularly the third, fourth, and eighth factors. 709 F.3d at 354. Courts should consider “whether a review of that evidence is required in order to ‘fill in gaps in the administrative record’” as to a particular Booth factor. Lockard v. Unum Life Ins. Co. of Am., No. 3:15cv21, 2015 WL 4730089, at *3 (N.D. W.Va. Aug. 10, 2015) (quoting Yelton v. ScanSource, Inc., 983 F.Supp.2d 683, 698 (D.S.C. 2013)).

         Here, Suter contends that her discovery requests are related to the third, fourth, and fifth Booth factors. Specifically, she seeks documents relating to previous claims that MetLife has received for Dependent Accidental Death and Dismemberment Insurance coverage or for claims in which MetLife relied on the relevant provisions of the Handbook, as well as all documents relating to the training of MetLife personnel with regard to such claims. Suter argues that these documents are necessary to assess whether MetLife has applied the relevant provisions consistently in previous claims, whether there are discrepancies between the training of claims evaluators and their decisionmaking in practice, and whether MetLife’s decision in her case was reasonable. Pl. Br. 7.

         Suter’s argument is insufficient as to her discovery requests regarding the training of MetLife employees. She has not explained how the requested information is necessary for the Court to evaluate any of the Booth factors or identified any gap in the record that this information would fill. Instead, Suter appears to seek “carte blanche to conduct discovery” on the question of employee training, which would “convert[] the emphasis of this litigation from the reasonableness of an administrator’s claim decision to an ‘exhaustive scrutiny of . . . the administrator’s business practices.’” Lockard, 2015 WL 4730089, at *4 (quoting Clark v. Unum Life Ins. Co. of Am., 799 F.Supp.2d 527, 533 (D. Md. 2011)). Discovery should not be permitted where, as here, the information is speculative and, in any event, does not appear to be necessary to resolution of the issues in the case.

         Suter has, however, shown that discovery may be necessary to fill gaps in the record as to previous interpretations of the relevant Plan provisions. As is evident from her Complaint, Suter’s primary argument in this matter focuses on a contested interpretation of language in the Handbook. See Compl. ¶¶ 8-14 (disputing MetLife’s use of a “sole and direct” causation standard in finding that the injuries Suter’s husband sustained in his accident were not the cause of death). The Administrative Record prepared by MetLife provides little explanation of how it interpreted Sections 1.1.5 and 1.1.6 and why it applied the standard it used in Suter’s benefits determination. See R. 112-13, 235-36. Information regarding MetLife‚Äôs application of this standard in prior cases would ...

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