The Eastern District of Kentucky permits plaintiff’s discovery due to MetLife’s alleged conflict of interest in an ERISA disability case.
Gary Dotson’s Disability Case
Before he became disabled, Gary Dotson was employed by CTI Foods Holdings, LLC. As a result of contracting the COVID-19 virus, Dotson became unable to continue working in August 2021. MetLife approved and paid disability benefits and then terminated benefits in July 2022. Dotson appealed MetLife’s termination, which MetLife rejected. Dotson then filed a lawsuit under the Employee Retirement Income Security Act (“ERISA”).
Aside from alleging breach of contract for failure to continue paying disability benefits, Dotson also claimed that MetLife had an inherent conflict of interest because it was responsible for paying benefits and deciding his entitlement to them.
During his lawsuit Dotson served discovery in the form of interrogatories request for production of documents, which MetLife claimed he was not entitled to under ERISA. Dotson moved to compel production of the requested documents and responses to the interrogatories.
The Court’s Decision
The Eastern District of Kentucky acknowledged that, while plaintiffs are typically not entitled to discovery in ERISA cases, the U.S. Supreme Court has held under MetLife Ins. Co. v. Glenn that limited discovery is available if a plaintiff satisfactorily alleges a violation of due process or bias by the plan administrator.
The court stuck to its prior decision in Busch v. Hartford Life & Acc. Ins. Co., which followed the holding in Glenn, that the presence of a conflict of interest—on its own—is sufficient to permit a court to allow discover beyond the insurance company’s claim file. Thus, the court granted Dotson’s motion to compel discovery.
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