The U.S. District Court for the Northern District of Texas, on February 19, 2016, granted in part and denied in part Dewayne Curtis’ motion to compel discovery from MetLife. While discovery in ERISA actions is generally limited, in this case, the court required MetLife to answer some of Mr. Curtis’ questions in the form of interrogatories.
The court required MetLife “to more fully describe the policy and methods used to determine compensation for the claims and appeals specialists who handled Plaintiff’s claim, such as any policy or method for determining and calculating bonuses, pay increases, or gain sharing.” However, MetLife was not required to provide compensation of supervisors as Mr. Curtis requested. The court also required MetLife to answer “whether and, if so, how the policy and methods used to determine compensation for the claims and appeals specialists who handled Plaintiff’s claim take account of” certain items listed in Mr. Curtis’ interrogatories. Regarding outside medical consultants, the court required MetLife “to generally describe what, if any, methods MetLife uses to monitor or impose quality assurance measures on the outside medical consultants or independent physician consultants involved with Plaintiff’s claims.”
While discovery in ERISA actions is generally limited, this case demonstrates some discovery courts may compel long term disability insurance companies to comply with. However, each case will require heavy fact specific analysis before a court may permit discovery.
Curtis v. Metro. Life Ins. Co., No. 3:15-CV-2328-B, 2016 WL 687164 (N.D. Tex. Feb. 19, 2016)