William Mason v. New York Life Insurance Company, et al.

Background

William Mason is a participant in an employee benefit plan provided through his employer, the American Jewish Committee. The plan provided long-term disability benefits. Mason worked as a Senior Desktop Engineer and was diagnosed with long COVID in October 2025. He submitted a claim for long-term disability benefits in November 2025, and New York Life Group Insurance Company of NY denied the claim in February 2026, finding that he was not eligible for benefits under the plan.

Mason’s amended complaint alleges that the defendants unlawfully denied his benefits in violation of the plan and the Employee Retirement Income Security Act of 1974, commonly called ERISA. The defendants include New York Life Group Insurance Company of NY, which the opinion identifies as the plan administrator and the entity fully insuring the plan, and New York Life Insurance Company. The defendants argued that New York Life Insurance Company should not be a party because it neither determines claims nor insures benefits; the opinion does not resolve that issue here.

Discovery Dispute

The parties disputed whether Mason should receive discovery beyond the administrative record—the information and documents known to the plan administrator when it made its final benefits decision. The court explained that review of an ERISA benefits denial is usually limited to that record. Additional evidence may be considered upon a showing of good cause, and the standard for obtaining discovery beyond the record is lower: the requesting party must show a reasonable chance that the discovery will support a later good-cause showing.

Mason sought discovery for two purposes: determining whether the administrative record was complete and examining New York Life Group Insurance Company of NY’s conflict of interest. The parties agreed that the company had a structural conflict because it both administered the plan and funded benefits. The court explained, however, that this conflict alone did not establish a sufficient basis for all of Mason’s requested discovery.

Ruling on Completeness Requests

Mason requested information about a potentially missing “feedback” report, review checklists, the employers of Robert Lane, Travis Thomas, and Will Jones, and documents deleted from the administrative record. The defendants identified the three employees as employees of Life Insurance Company of North America.

The court permitted Mason to serve targeted interrogatories, which are written questions, and/or targeted document requests concerning three subjects: the potentially missing feedback report, the review checklists, and information about documents deleted from the administrative record. The court found that a deposition of a corporate representative about the completeness of the administrative record was not proportional to the needs of the case.

Ruling on Conflict-of-Interest Requests

Mason sought information about in-house file reviewers Dr. Yvette Yeung and Dr. Fidelis Mkparu, including the number of their reviews, samples of reports, and how often they concluded that claimants could or could not work. The court found that Mason had not shown a reasonable chance that this discovery would support a good-cause showing. It also independently found that the requests were not proportional to the needs of the case because raw numbers or percentages of claim decisions lacked sufficient context. The court therefore did not grant this category of discovery.

Mason also sought information about financial incentives for Robert Lane, Travis Thomas, Dr. Yeung, and Dr. Mkparu for 2025 and 2026. The court found a reasonable chance that this information could support a good-cause showing because incentives tied to approving or denying benefits could be relevant to possible biased decision-making. The court ordered the defendants to produce documents stating the bases on which those employees may have received incentive compensation and documents sufficient to show financial incentives provided to them during those years.

Finally, Mason sought performance evaluations for those four employees for 2025 and 2026. The court found that he had shown a reasonable chance that the evaluations could support a good-cause showing because the way employees’ performance was measured could bear on whether the conflict of interest affected the benefits decision. The court ordered the defendants to produce those evaluations.

Order and Schedule

Judge Stewart D. Aaron ordered that Mason was granted only the specified discovery: targeted written questions or document requests about the three record-completeness topics, documents about the four employees’ financial incentives, and their performance evaluations for 2025 and 2026. The defendants were required to produce the ordered documents within 14 days of the order.

The court also set deadlines: motions to amend or join additional parties were due by September 3, 2026; fact discovery was to be completed by November 30, 2026; and any motion by Mason for permission to conduct expert discovery was due by December 14, 2026. This order addressed discovery and case scheduling, not the ultimate merits of Mason’s claim for long-term disability benefits.