Silverstone v. Reliance Standard Life Insurance Company
MEMORANDUM OPINION AND ORDER denying 15 MOTION for Discovery filed by Amy Silverstone. Signed by Judge Paula Xinis on 11/16/2017. (jf3s, Deputy Clerk)
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
Civil Action No. PX 17-0111
RELIANCE STANDARD LIFE
MEMORANDUM OPINION AND ORDER
Plaintiff Amy Silverstone brings suit against Defendant Reliance Standard Life Insurance
Company (“Reliance”), alleging that Reliance violated the Employee Retirement Income
Security Act (“ERISA”), 29 U.S.C. § 1132(a)(1)(B), by improperly denying her claim for longterm disability benefits. ECF No. 1 at ¶ 3. Pending before the Court is Plaintiff’s motion to
compel extra-record discovery. ECF No. 15. The issue has been fully briefed by the parties.
Upon consideration, the motion is DENIED.
In Metropolitan Life Insurance Co. v. Glenn, 554 U.S. 105 (2008), the United States
Supreme Court recognized a narrow exception to the rule that a district court’s review of a plan
administrator’s decision is limited to the administrative record. The Metropolitan Life Court
held that when a plan administrator both evaluates and pays claims for benefits, a conflict of
interest exists and extra-record discovery may be appropriate to determine the effect of that
conflict on the administrator’s decision. Id. at 112–13, 117–18.
However, for a court to permit discovery, a plaintiff must demonstrate that the
administrative record does not contain enough information to allow the district court to weigh
properly the conflict of interest in reaching its conclusion, and the discovery sought must be
appropriately narrow. See Clark v. Unum Life Ins. Co. of Am., 799 F. Supp. 2d 527, 533 (D. Md.
2011); Anderson v. Reliance Standard Life Ins. Co., Civ. No. WDQ-11-1188, 2012 WL 32568, at
*3 (D. Md. Jan. 5, 2012).
Silverstone has failed to identify any specific need for extra-record discovery consistent
with Metropolitan Life.1 See Patel v. United of Omaha Life Ins. Co., Civ. No. DKC-12-0880,
2012 WL 2370129, at *3 (D. Md. June 21, 2012) (denying request where no basis for the Court
to determine whether any gaps in the administrative record warrant outside discovery was
provided and no showing that the evidence in the record was deficient was made). Instead, in
her initial motion, the Plaintiff made only generalized allegations of “potential” bias. See
generally ECF No. 15-1 at 2–4. Moreover, as the Defendant rightfully points out, the record
appears to include evidence sufficient to determine whether bias affected Defendant’s decision.
ECF No. 18-1 at 5–6; see Anderson, 2012 WL 32568 at *3 (discussing Clark and noting that on
the basis of evidence in the record identified by the defendant the district court determined that
the record contained sufficient information to allow the Court to determine the appeal on the
record); Patel, 2012 WL 2370129 at *3 (same).
Although Silverstone argues that she is entitled to evidence related to “any history of biased claims
administration,” “steps taken by the claims administrator to reduce the potential conflict of interest,” and “referral
practices and outcomes with a particular medical provider,” ECF No. 19 at 2–3, these requests are neither
sufficiently tied to the record in this case nor sufficiently narrow. Cf. Anderson, 2012 WL 32568 at *3 (discussing
specific conflict-of-interest allegations raised by the plaintiff and determining that “certain limited additional
discovery may shed light” on the allegations).
Therefore, it is this 16th day of November, 2017, hereby ORDERED that:
The Motion for Discovery filed by Plaintiff AMY SILVERSTONE (ECF No. 15) BE,
and the same hereby IS, DENIED;
The Clerk is directed to transmit copies of this Memorandum Opinion and Order to
counsel for the parties.
United States District Judge
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