Toven v. Metropolitan Life Insurance Company

Summary

The court denied Metropolitan Life Insurance Company's motion for a protective order seeking to prohibit depositions in an ERISA disability-benefits dispute. Applying Abatie v. Alta Health & Life Insurance Co., the court held that discovery beyond the administrative record may be appropriate to examine the nature, extent, and effect of a structural conflict of interest on the claims decision-making process.

Holdings

1. In an ERISA benefits case subject to abuse-of-discretion review, the court may consider evidence outside the administrative record to determine the nature, extent, and effect of a plan administrator's conflict of interest on its decision-making.
2. MetLife was not entitled to a protective order prohibiting the depositions because the requested discovery could lead to information relevant to the nature, extent, and effect of MetLife's conflict of interest.

Questions Presented

1. Whether discovery beyond the ERISA administrative record may be permitted in an action reviewed under an abuse-of-discretion standard when the plan administrator has a conflict of interest.
2. Whether MetLife was entitled to a protective order prohibiting depositions of its claims representatives and consulting physician.

Disposition

other