Maher v. Prudential Insurance Company of America et al
Opinion and Order. Plaintiff's Motion for Limited Discovery (Related doc # 16 ) is denied. Judge Christopher A. Boyko on 7/6/2015. (H,CM)
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF OHIO
MELISSA J. MAHER,
THE PRUDENTIAL INSURANCE
COMPANY OF AMERICA, et al.,
CASE NO. 1:14CV2777
JUDGE CHRISTOPHER A. BOYKO
OPINION AND ORDER
CHRISTOPHER A. BOYKO, J.:
This matter comes before the Court upon the Motion (ECF DKT #16) of Plaintiff,
Melissa J. Maher, for Limited Discovery. For the following reasons, the Motion is denied.
The above-captioned case arises under the Employee Retirement Income Security Act
of 1974 (“ERISA”), 29 U.S.C. § 1001, et seq. Plaintiff seeks long-term disability benefits
(“LTD”) under a plan, sponsored by her employer, Bonne Bell, LLC, and administered by
Defendant Prudential. Plaintiff claims that her LTD benefits were wrongfully terminated.
Plaintiff seeks limited discovery, by way of deposition, of the Senior Claims Examiner and a
Fed.R.Civ.P. 30(b)(5) corporate representative of Prudential, “in order to discern the validity
of the Administrative Record.” Plaintiff asserts that “there appears [sic] to be documents that
“should” be in the Administrative Record that are not.” (ECF DKT #16 at 3).
II. LAW AND ANALYSIS
As a general principle in the Sixth Circuit, an ERISA claimant may not seek discovery
of evidence outside of the administrative record. Wilkins v. Baptist Healthcare Sys., Inc., 150
F.3d 609, 618-619 (6th Cir.1998). In fact, the district court is restricted to reviewing the
administrative record as it existed when the plan administrator made its final decision. Id. at
615. “If the administrative record so limited can support a ‘reasoned explanation’ for
[Prudential’s] decision, the decision is not arbitrary or capricious.” Moon v. Unum Provident
Corp., 405 F.3d 373, 379 (6th Cir.2005), citing Williams v. Int’l Paper Co., 227 F.3d 706, 712
(6th Cir.2000). The narrow exception to this limitation is for evidence going to a “procedural
challenge to the administrator’s decision, such as an alleged lack of due process afforded by
the administrator or alleged bias on its part.” Cooper v. Life Insurance Company of North
America, etc., 486 F.3d 157 (6th Cir.2007); Wilkins, 150 F.3d at 619. Evidence outside the
record may be considered only as it relates to the procedural defect of lack of due process,
bias or conflict of interest. See Mulligan v. Provident and Life Acc. Ins. Co., 271 F.R.D. 584
In the matter before the Court, Prudential provided Plaintiff with documents, on or
about May 7, 2015, purporting to be the Administrative Record for her claim. Tamika S.
Williams, a Claims Litigation Specialist at Prudential, certifies that the entire claim file has
been provided to Plaintiff. (ECF DKT #17-1). She avers: “The claim file contains all
information received by Prudential in reviewing Plaintiff’s claim for long-term disability
benefits, as well as a full record of Prudential’s analysis of Plaintiff’s claim and appeals.” (Id.
at ¶ 3).
In her Motion, Plaintiff fails to allege any procedural irregularity and does not point to
any lack of due process or bias or conflict of interest. Plaintiff does contend, though, that
“there appears to be more records that should be within the Administrative Record.” (ECF
DKT #16 at 4). (Emphasis added). She notes that the Administrative Record provided to her
has no medical review dated prior to the initial approval of LTD on September 19, 2012.
Prudential points out that Plaintiff is in error. The Administrative Record includes
documentation of the medical review and of the medical records relied upon by Prudential
when it initially granted benefits. (ECF DKT #17-1 & #17-2). Per Ms. Williams’ sworn
Declaration, the Record is complete.
Plaintiff’s bare speculation about deficiencies in the Administrative Record does not
justify even limited discovery. Plaintiff’s Motion (ECF DKT #16) for Limited Discovery is
not warranted and is, therefore, denied.
IT IS SO ORDERED.
s/ Christopher A. Boyko
CHRISTOPHER A. BOYKO
United States District Judge
Dated: July 6, 2015
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