Perez v. Unum Life Insurance Company Of America
- Edward Davila
- 5:21-cv-03207
- U.S. District Court · Northern District of California
- 2
In Perez v. Unum Life Insurance Company Of America, Judge Davila denied Perez’s request to overturn a magistrate judge’s discovery ruling about the administrative record.
The ruling affected Robert Perez’s request for additional discovery concerning whether the administrative record was complete.
What happened
In Perez v. Unum Life Insurance Company Of America, Robert Perez asked the district court to set aside part of a pretrial ruling by Magistrate Judge Susan van Keulen. The dispute involved whether the record used in deciding Perez’s matter was complete.
Perez argued that there were enough grounds for more discovery—additional information-gathering—to determine whether documents had been left out of the administrative record. Unum confirmed that it had produced the complete claim file, and the court found Perez’s concerns about the record insufficient.
Judge Edward J. Davila held that the magistrate judge’s ruling was not clearly erroneous or contrary to law. The court therefore denied Perez’s motion for relief.
The detailed version
- Perez v. Unum Life Insurance Company Of America · No. 5:21-cv-03207
- Edward Davila
- Mar. 1, 2022
Background
Robert Perez moved for relief from a nondispositive pretrial order entered by Magistrate Judge Susan van Keulen. He challenged disputed issues 1 and 2, which concerned whether additional discovery was warranted regarding the completeness of the administrative record—the materials being used in the matter.
Perez argued that there were insufficient grounds for Judge van Keulen’s conclusion that further discovery was not justified. The opinion does not describe the underlying claim between Perez and Unum beyond this discovery dispute.
Legal standard
A district judge may set aside or modify a magistrate judge’s ruling on a nondispositive motion only if the ruling is clearly erroneous or contrary to law. Factual findings are reviewed for clear error, meaning the district court must have a definite and firm conviction that a mistake was made. Legal conclusions are reviewed to determine whether they are contrary to law.
Court’s analysis
The court reviewed Judge van Keulen’s order and the parties’ briefing but could not find clear error or a ruling contrary to law. The court said the record supported Judge van Keulen’s determination that Unum had not removed documents from the administrative record.
The court relied first on Unum’s confirmation that it had produced the complete claim file. It also found that Perez’s attempts to cast doubt on the record’s completeness were insufficient. In particular, the identified 20-day period did not raise questions about whether the record was complete.
Disposition
Judge Edward J. Davila denied Perez’s motion for relief from the nondispositive pretrial order. The order did not state that the motion was denied with or without prejudice.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.