Staley v. Metropolitan Life Insurance Company
- Haywood Gilliam
- 4:20-cv-09497
- U.S. District Court · Northern District of California
- 2
In Staley v. Metropolitan Life Insurance, Judge Gilliam granted Staley’s request for discovery beyond the ERISA administrative record.
Sharae M. Staley may obtain discovery beyond the administrative record. Metropolitan Life Insurance Company must produce the requested claim materials within 30 days and participate in scheduling depositions of two claims adjusters.
What happened
In Staley v. Metropolitan Life Insurance Company, Sharae M. Staley sued Metropolitan Life Insurance Company under the Employee Retirement Income Security Act, alleging that it failed to provide benefits and breached fiduciary duties.
The court decided that the plan gave Metropolitan Life discretion to administer claims, so an abuse-of-discretion standard would apply. The court also found that additional discovery was warranted and allowed Staley to seek information beyond the administrative record, including claims materials and depositions of two claims adjusters.
Judge Haywood S. Gilliam, Jr. granted Staley’s discovery request. He ordered Metropolitan Life to produce the requested materials within 30 days and directed the parties to meet and confer about scheduling the depositions.
The detailed version
- Staley v. Metropolitan Life Insurance Company · No. 4:20-cv-09497
- Haywood Gilliam
- Apr. 30, 2021
Background
Sharae M. Staley brought an action under the Employee Retirement Income Security Act (ERISA) against Metropolitan Life Insurance Company, alleging failure to provide benefits and breach of fiduciary duties. At a case management conference, the court ordered supplemental briefing about the scope of discovery.
Standard of Review
Metropolitan Life argued that the court should review its benefits decision for abuse of discretion. The court agreed because the ERISA plan gave Metropolitan Life discretionary authority, and the opinion states that Staley had not shown otherwise.
Discovery Ruling
Staley argued that additional discovery was warranted for her claim seeking equitable relief under 29 U.S.C. § 1132(a)(3) based on an alleged breach of fiduciary duty. She requested depositions of two Metropolitan Life claims adjusters, the complete claim file, and the claims-manual guidelines. Metropolitan Life did not dispute that the court had discretion to allow discovery concerning an alleged conflict of interest.
The court, exercising its discretion, granted Staley’s request for discovery beyond the administrative record. It directed Metropolitan Life to produce the requested materials within 30 days and directed the parties to meet and confer to schedule the two depositions. The order addressed discovery and did not decide the underlying benefits or fiduciary-duty claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.